# Local File: Aegean Crest Shipping One Ltd
Financial year 2025. Prepared with tp.alp for Aegean Crest Shipping.

> **DRAFT — NOT SIGNED OFF.** 3 of 3 sections are not confirmed. Not for filing.

## 1. The local entity
Aegean Crest Shipping One Ltd is a company resident in Cyprus. Single-ship company: owns m/v Aegean Dawn and bareboat-charters her to Navigation Inc.; a qualifying owner under tonnage tax; its bank loan is guaranteed by Navigation Inc.
Group: Aegean Crest Shipping. Entities in the group: Aegean Crest Navigation Inc. (CY); Aegean Crest Navigation II Inc. (CY); Aegean Crest Ship Management Ltd (CY); Aegean Crest Chartering Ltd (CY); Aegean Crest Agencies Ltd (GB); Aegean Crest Holdings Corp. (MH); Aegean Crest Shipping One Ltd (CY); Aegean Crest Shipping Two Ltd (CY); Aegean Crest Shipping Three Inc. (CY); Aegean Crest Shipping Four Inc. (LR).
Documentation duty: financing, by its maximum principal, of €18,000,000 exceeds the €5,000,000 threshold the Tax Department publishes.

_Sources: Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022, section 33(7)–(8); Tax Department, Frequently Asked Questions about Transfer Pricing, question 52; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 3, 9 and 10; OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II_
_Status: draft. Content hash 0f6ba545b66fd72c1a4fc7e9f23f91610cc166c06dcb7ff0b2c1b0e57f4794cb._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Guarantee of Shipping One's bank loan
Guarantee of Shipping One's bank loan: Aegean Crest Navigation Inc. to Aegean Crest Shipping One Ltd, no fee charged, on a maximum guaranteed amount of €18,000,000.
Method: No guarantee fee charged; no written agreement. Tested party: Aegean Crest Navigation Inc.
A guarantee: no safe harbour rate applies.
No written agreement on file.
Risk allocation: Guarantor bears the risk of the single-ship company defaulting.

_Sources: OECD Transfer Pricing Guidelines 2022, paragraph 1.36; OECD Transfer Pricing Guidelines 2022, paragraphs 10.161–10.177; Tax Department, Frequently Asked Questions about Transfer Pricing, question 5_
_Status: draft. Content hash 92f88b69120d4d2e672a29de32dce9507a72996e755f2dc0dad101fe469f364c._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 3. Financial information
Financial information used in the analysis: Management accounts 2025, Aegean Crest companies (SHA-256 eaabf9be89019375…).
Guarantee of Shipping One's bank loan: maximum guaranteed amount €18,000,000; no fee charged; tenor not on file.

_Sources: OECD Transfer Pricing Guidelines 2022, Chapter V, Annex I and Annex II; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 3, 9 and 10_
_Status: draft. Content hash 169a47056b656877c306904d8febc6397fa881ed56df0a175429c51f06d151db._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet