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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.

Which threshold, for which year. For tax years 2022 to 2025 the Tax Department publishes €1,000,000 per category and €5,000,000 for financial transactions (Tax Dept FAQ Q52), above the statute's own €750,000 (ITL s.33(9)(α)). The conclusion follows the published thresholds; the statute is shown beside them. From tax year 2026 the law itself sets €2,500,000, €5,000,000 for goods and €10,000,000 for financing (L.244(I)/2025 s.17). A loan counts by its maximum principal in the year, not its interest (Tax Dept FAQ Q9–10).

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 required

Incorporated 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

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
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))
€1,000,000Yes€750,000Yes
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))
€5,000,000Yes€750,000Yes

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)).

Left out of the threshold and the Summary Table:
  • 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

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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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Aegean Crest Navigation II Inc.

Local File required

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

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
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))
€5,000,000Yes€750,000Yes

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)).

Left out of the threshold and the Summary Table:
  • 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

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Aegean Crest Ship Management Ltd

No Local File

Technical 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.

Left out of the threshold and the Summary Table:
  • 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

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Evidence still outstanding: Tonnage tax certificates for the owners and the manager, due 12 Nov 2026 — in 5 days.

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Aegean Crest Chartering Ltd

Local File required

Chartering desk: finds cargoes and fixes the vessels for a commission; not a qualifying activity, so under income tax

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
Services (1 transaction)€1,235,000€1,000,000Yes€750,000Yes

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)).

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Aegean Crest Shipping One Ltd

Local File required

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.

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
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))
€5,000,000Yes€750,000Yes

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)).

Left out of the threshold and the Summary Table:
  • 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

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Aegean Crest Shipping Two Ltd

Local File required

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

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
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))
€5,000,000Yes€750,000Yes

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)).

Left out of the threshold and the Summary Table:
  • 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

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Aegean Crest Shipping Three Inc.

No Local File

Incorporated 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.

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
Financing (1 transaction, by maximum principal)€2,100,000€5,000,000No€750,000Yes

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)).

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