# Local File: Aegean Crest Shipping Two 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 Two Ltd is a company resident in Cyprus. Single-ship company: owns m/v Aegean Spirit, delivered in 2025, funded by Navigation Inc. and bareboat-chartered to her; a qualifying owner under tonnage tax.
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 €9,000,000 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 1216db780409c73b590a12547ec9117c26a2a636deec4bfb9dccce3959f26f9c._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet

## 2.1 Newbuilding loan to Shipping Two
Newbuilding loan to Shipping Two: Aegean Crest Navigation Inc. to Aegean Crest Shipping Two Ltd, interest €405,000 in the year on a maximum principal of €9,000,000.
Method: Interest at 4.5%, set by the group; never tested. Tested party: Aegean Crest Navigation Inc.
Circular 6/2023 safe harbour: not available: the category is over the threshold.
No written agreement on file.
Risk allocation: Lender bears the credit risk of the borrower; the vessel is mortgaged to the bank, not to the lender.

_Sources: OECD Transfer Pricing Guidelines 2022, paragraph 1.36; Tax Department, Frequently Asked Questions about Transfer Pricing, questions 13, 31 and 42_
_Status: draft. Content hash fc75d5dbb7f40a67a48cfd52b7a2a91de5b938d43980383aa961f5c04a45c5a0._
- 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…).
Newbuilding loan to Shipping Two: maximum principal €9,000,000; rate 4.50%; tenor not on file; interest in the year €405,000.

_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 ac4263c66ca00fe287de453d85d11cc418ca052b021d58202ac9ad496cf5a94d._
- Reviewed: not yet
- Verified: not yet
- Confirmed: not yet