I. Introduction
Although internationally adopted, the expression "tax
haven" has not been used in the Brazilian applicable
legislation. Brazilian regulatory authorities do not like offshore
jurisdictions, considered as "tax havens", because they
believe that these jurisdictions have been misused in general with
the specific purpose of (i) avoiding the payment of local
taxes and/or (ii) not disclosing the identity of the true
beneficiaries of the assets (which could be Brazilian residents
pretending to be foreign investors just to avoid the reporting and
other compliance requirements) and many times to facilitate
transactions which would be regarded as questionable or illegal in
the jurisdiction of domicile of the true beneficiaries. The fact is
that the traditional offshore jurisdictions, the so-called
"tax haven jurisdictions", have a bad image in many
countries and not only in Brazil.