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 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: 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 Shipping Two Ltd (draft).

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Rests on, not yet confirmed: Obligations: Aegean Crest Shipping Two Ltd.

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2.1 Newbuilding loan to Shipping Two

Draft

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 1.36; Tax Dept FAQ Q31. Rests on: Financing: Newbuilding loan to Shipping Two (draft).

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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.

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3. Financial information

Draft

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

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