Reference is made to the annual report on Form 20-F of Top Ships Inc. (the “Company”) for the year ended December 31, 2025 (the “Annual Report”) and the Registration Statements on
Form F-3 (File Nos. 333-267170 and 333-268475) and the post-effective Amendment to Form F-1 in the Registration Statement on Form F-3 (File No. 333-267545) of the Company including the prospectuses contained therein (together, the “Registration
Statements”). We hereby consent to (i) the filing of this letter as an exhibit to the Annual Report, which is incorporated by reference into the Registration Statements and (ii) each reference to us and the discussions of advice provided by us in
the Annual Report under the section “Item 10. Additional Information—E. Taxation” and to the incorporation by reference of the same in the Registration Statements, in each case, without admitting we are “experts” within the meaning of the
Securities Act of 1933, as amended, or the rules and regulations of the U.S. Securities and Exchange Commission promulgated thereunder with respect to any part of the Registration Statements.