Engagements › Aegean Crest Shipping › Local File

Local File

Assembled section by section for each entity that owes one. Each section shows what it rests on and where it stands. Content follows OECD Ch. V, Annexes I–II.

Assembled section by section; exports as final only when confirmed.

Aegean Crest Navigation Inc.Aegean Crest Navigation II Inc.Aegean Crest Chartering Ltd Aegean Crest Shipping One Ltd Aegean Crest Shipping Two Ltd

DRAFT — not signed off. 3 of 3 sections are not yet confirmed; an export now carries the draft mark. Export Draft On iPad: Print → Save as PDF for a readable copy. Export As Final — export as final once all 3 sections are confirmed, 3 to go

1. The local entity

Draft

Aegean Crest Navigation II Inc. is taken to be a company resident in Cyprus by management and control, to be confirmed by the practice. Incorporated in the Marshall Islands; if managed and controlled from Limassol (board minutes requested), tax resident in Cyprus. Owns two Supramax vessels; 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 €6,500,000 exceeds the €5,000,000 threshold the Tax Department publishes.

Sources: ITL s.2; ITL s.33(7)–(8); Tax Dept FAQ Q52; Tax Dept FAQ Q9–10; OECD Ch. V, Annexes I–II. Rests on: Obligations: Aegean Crest Navigation II Inc. (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Obligations: Aegean Crest Navigation II Inc.

Next: Reviewed, by a team member. Choose a person under View As to sign.

Hash

Content hash 91e8a4dce324 · a change to it reopens every sign-off

2.1 Loan to the sister owner for a vessel purchase

Draft

Loan to the sister owner for a vessel purchase: Aegean Crest Navigation Inc. to Aegean Crest Navigation II Inc., interest €325,000 in the year on a maximum principal of €6,500,000.

Method: Interest at 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.

Sources: OECD 1.36; Tax Dept FAQ Q31. Rests on: Financing: Loan to the sister owner for a vessel purchase (draft).

Sign-Off

ReviewedVerifiedConfirmed

Rests on, not yet confirmed: Financing: Loan to the sister owner for a vessel purchase.

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Accounts for 2022, 2023 and 2024 for every Cyprus company, due 12 Nov 2026 — in 5 days.

Evidence still outstanding: Board minutes showing management and control in Limassol, due 17 Nov 2026 — in 10 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

Hash

Content hash 25f63bf1d111 · a change to it reopens every sign-off

3. Financial information

Draft

Financial information used in the analysis: Management accounts 2025, Aegean Crest companies (SHA-256 eaabf9be89019375…).

Loan to the sister owner for a vessel purchase: maximum principal €6,500,000; rate 5.00%; tenor not on file; interest in the year €325,000.

Sources: OECD Ch. V, Annexes I–II; Tax Dept FAQ Q9–10.

Sign-Off

ReviewedVerifiedConfirmed

Next: Reviewed, by a team member. Choose a person under View As to sign.

Hash

Content hash 1ab125e16e25 · a change to it reopens every sign-off