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The first thing you notice when analysing the tax haven lists of the six Latin American countries that do have them is their heterogeneity.a) Only 17 jurisdictions are included in ALL the 6 active blacklists of Brazil, Mexico, Ecuador, Colombia, Peru and El Salvador.The decision of the Federal Tax Administration (Receita Federal) of Brazil to add Ireland took place within the context of institutional weakness with respect to the Federal Government of Brazil as a result of the dismissal of President Dilma Roussef and her replacement by a ‘pro-market’ government that is more in favour of deregulation.
The debate should go to the very heart of taxation systems, which were designed nationally in each country based on the economic realities experienced at the beginning of the twentieth century and are ineffective for taxing multinationals today.
A special rule was created around this in 2014 which meant Hungary was taken off the grey list (now Hungary has decided to drop its corporate tax rate to 9% Brazil should reassess its position).
This newish rule explains why countries like Slovenia (17%), Czech Republic (19%), Poland (19%) and the UK (19%) are not on Brazil’s black or grey lists.
This case demonstrates the profound heterogeneity of treatment given by the tax laws of Latin American countries to the territories and countries that are part of the Tax Haven Network.
The Brazilian blacklist carries the most weight in Latin America due to the size of its population and market.