Engagements › Aegean Crest Shipping › Obligations
Obligations
What each Cyprus entity owes for financial year 2025 — Local File, Summary Information Table (the Summary Table, for short), Master File — from its controlled transactions, each rule cited. Foreign entities are outside this practice's library and are not assessed here.
Which documents each Cyprus entity owes, each threshold cited.
Master File, for the group: only an Ultimate or Surrogate Parent Entity keeps one (ITL s.33(9)(β)), and a group under €750,000,000 of consolidated revenue is outside it (L.205(I)/2012 Annex III). On the revenue on file (€1,260,000,000 for 2024, Consolidated accounts of Aegean Crest Holdings Corp., the ultimate parent (invented), to be confirmed) the group is over €750,000,000: its ultimate parent keeps a Master File; none of the Cyprus companies is the ultimate parent — Aegean Crest Holdings Corp. (MH) is, so none of them keeps one here unless one is named the Surrogate Parent Entity — to be confirmed by the practice.
Country-by-country report, for 2025: the group is over €750,000,000 for 2024, so it reports. The Ultimate Parent Entity, Aegean Crest Holdings Corp. (MH), files where it is resident; whether a Cyprus company must file in its place (Annex III, Section II point 1) turns on that jurisdiction's rules and agreements with Cyprus — to be confirmed by the practice. Each Cyprus company notifies who files by 31 Dec 2025 — past; whether it was made is to be established; the report is due by 31 Dec 2026 (L.205(I)/2012 s.7Γ, L.205(I)/2012 Annex III §II.3–4, L.205(I)/2012 Annex III).
Aegean Crest Navigation Inc.
Local File requiredIncorporated in the Marshall Islands; if managed and controlled from Limassol (board minutes requested), tax resident in Cyprus. Owns three dry bulk carriers and operates three more bareboat-chartered in from the single-ship companies; a qualifying owner under tonnage tax
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Services (2 transactions) | €2,210,000 to be confirmed by the practice (how a guarantee is measured against the threshold is not stated in the FAQ (question 5)) | €1,000,000 | Yes | €750,000 | Yes |
| Financing (3 transactions, by maximum principal) | €33,500,000 to be confirmed by the practice (how a guarantee is measured against the threshold is not stated in the FAQ (question 5)) | €5,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Ship management of the bulk carriers, €1,900,000 — Both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner Tax Dept FAQ Q22–24
- Chartering commissions, €1,235,000 — The owner is under tonnage tax and the chartering desk is not: only the chartering desk's income-taxed side counts (FAQ question 23) Tax Dept FAQ Q22–24
- Interest-free shareholder loan from the parent, €14,000,000 (principal) — An interest-free payable: left out for the company that owes it (2022–2026) Tax Dept FAQ Q25
- Bareboat charter of m/v Aegean Dawn, €2,900,000 — Both parties are under tonnage tax: bareboat chartering between two qualifying owners Tax Dept FAQ Q22–24
- Bareboat charter of m/v Aegean Spirit, €2,600,000 — Both parties are under tonnage tax: bareboat chartering between two qualifying owners Tax Dept FAQ Q22–24
- Sale proceeds left with Navigation Inc., €2,100,000 (principal) — An interest-free payable: left out for the company that owes it (2022–2026) Tax Dept FAQ Q25
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 It rests on a point not settled in the sources read — whether interest between two tonnage tax owners is qualifying income; whether the agency fee falls outside the table by analogy to FAQ Q23 (Q23 is about a Party B under Cyprus income tax; the UK agency is not); whether bareboat chartering out is a qualifying shipping activity of the owner under the Merchant Shipping law; measuring the guarantee by the guaranteed amount; whether a tonnage tax owner's charter from a related company outside the Cyprus tonnage tax system counts — to be confirmed by the practice. Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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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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Content hash70f6ccf0e29e · a change to it reopens every sign-offAegean Crest Navigation II Inc.
Local File requiredIncorporated 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
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Financing (1 transaction, by maximum principal) | €6,500,000 to be confirmed by the practice (how a guarantee is measured against the threshold is not stated in the FAQ (question 5)) | €5,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Ship management of the Supramaxes, €1,350,000 — Both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner Tax Dept FAQ Q22–24
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 It rests on a point not settled in the sources read — whether interest between two tonnage tax owners is qualifying income — to be confirmed by the practice. Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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Content hashf1e744bbbe79 · a change to it reopens every sign-offAegean Crest Ship Management Ltd
No Local FileTechnical management of the group's eight vessels: the five owned by the two Navigation companies and the three bareboat-chartered in by Navigation Inc.; a qualifying ship manager under tonnage tax
No controlled transactions that count in the year.
- Ship management of the bulk carriers, €1,900,000 — Both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner Tax Dept FAQ Q22–24
- Ship management of the Supramaxes, €1,350,000 — Both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner Tax Dept FAQ Q22–24
- Local File: not required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52
- Summary Information Table: no transactions to report (left out under Tax Dept FAQ Q22–24); whether a nil table is still filed is to be confirmed by the practice (the FAQs say what is left out; they do not say whether a table with nothing in it is filed) (Tax Dept FAQ Q51: the return's question 50 is answered YES).
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Evidence still outstanding: Tonnage tax certificates for the owners and the manager, due 12 Nov 2026 — in 5 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
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Content hash321a99e3c895 · a change to it reopens every sign-offAegean Crest Chartering Ltd
Local File requiredChartering desk: finds cargoes and fixes the vessels for a commission; not a qualifying activity, so under income tax
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Services (1 transaction) | €1,235,000 | €1,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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Content hashf452321a7712 · a change to it reopens every sign-offAegean Crest Shipping One Ltd
Local File requiredSingle-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.
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Financing (1 transaction, by maximum principal) | €18,000,000 to be confirmed by the practice (how a guarantee is measured against the threshold is not stated in the FAQ (question 5)) | €5,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Bareboat charter of m/v Aegean Dawn, €2,900,000 — Both parties are under tonnage tax: bareboat chartering between two qualifying owners Tax Dept FAQ Q22–24
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 It rests on a point not settled in the sources read — whether bareboat chartering out is a qualifying shipping activity of the owner under the Merchant Shipping law; measuring the guarantee by the guaranteed amount — to be confirmed by the practice. Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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Content hashf786c1f21639 · a change to it reopens every sign-offAegean Crest Shipping Two Ltd
Local File requiredSingle-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
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Financing (1 transaction, by maximum principal) | €9,000,000 to be confirmed by the practice (how a guarantee is measured against the threshold is not stated in the FAQ (question 5)) | €5,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Bareboat charter of m/v Aegean Spirit, €2,600,000 — Both parties are under tonnage tax: bareboat chartering between two qualifying owners Tax Dept FAQ Q22–24
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 It rests on a point not settled in the sources read — whether bareboat chartering out is a qualifying shipping activity of the owner under the Merchant Shipping law; whether interest between two tonnage tax owners is qualifying income — to be confirmed by the practice. Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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Content hasheaff2c1a5720 · a change to it reopens every sign-offAegean Crest Shipping Three Inc.
No Local FileIncorporated in the Marshall Islands; if managed and controlled from Limassol (board minutes requested), tax resident in Cyprus. Single-ship company and a qualifying owner under tonnage tax until the sale: sold m/v Aegean Star in March 2025 and is now dormant; the sale proceeds were left with Navigation Inc.
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Financing (1 transaction, by maximum principal) | €2,100,000 | €5,000,000 | No | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Local File: not required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 On the statute's €750,000 alone it would be required. Under the threshold: the simplified documentation of Circular 6/2023, or its safe harbours where they fit (Tax Dept FAQ Q31).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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