How the state of Delaware was used in the USA to protect 72 billion Brazilian reals from “the largest debtor in the country”

The target of a massive operation launched on Thursday morning against a tax fraud scheme, the Refit Group is suspected of transferring more than R$72 billion, in just one year, to hide profits through offshore companies in the US state of Delaware. According to the IRS, the location was chosen because it allows the creation of anonymous companies and without local taxes that do not generate income in North American territory. This structure means that the entities are no longer subject to taxation in both the United States and Brazil and, according to the IRS, are “typically associated with strategies aimed at money laundering or asset protection.”

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According to investigations, one of the main international operations carried out by foreign entities was the acquisition of an export company in Houston, Texas, which generated more than R$12.5 billion between 2020 and 2025. The IRS has already identified more than 15 offshore companies in the United States, which are sending resources to purchase stocks and real estate in Brazil, totaling about R$ 1 billion.

“It was also revealed that financial transfers abroad amounting to more than 1.2 billion Brazilian reais in the form of loan contracts convertible into shares, which could return to Brazil as investments through other offshore companies,” the agency explained.

In practice, criminals used companies, investment funds, and offshore companies to hide and protect their profits. According to the IRS, the fraudulent operations are run by the same group, which controls financial companies and uses international structures to protect assets.

As part of the same operation, called Poço de Lobato, the São Paulo court also ordered the freezing of assets worth R$10.2 billion owned by members of the Refit Group. This action was taken by the Interinstitutional Commission for Asset Recovery of São Paulo State (Cira-SP), which opened a criminal investigation since the group is the country’s “largest persistent tax debtor” – an expression referring to those who, intentionally, do not comply with their financial obligations.

The massive operation launched this morning has fulfilled arrest warrants in five states: São Paulo, Rio de Janeiro, Minas Gerais, Bahia and Maranhão, as well as the Federal District. In total, there are 126 injunctions against 190 targets linked to Revit Group, owner of the former Manguinhos refinery in Rio de Janeiro, and dozens of companies in the fuel sector.

The group is headed by businessman Ricardo Magro, and is the largest ICMS city in the state of São Paulo and one of the largest in the federation. According to the Ministry of Public Affairs in São Paulo, the “innovative” tax fraud scheme is organized It caused losses to the states and the Union estimated that more than R$26 billion of debt was already registered in active debt.

More than 190 targets, including individuals and legal entities, are suspected of being part of these attacks Criminal organization And practice Various crimes against the economic and tax system, money laundering, among other violations. The process includes the participation of more than 621 public employees.

According to investigations, several companies associated with the Refit group are trying to evade the responsibility of collecting ICMS owed to the state of São Paulo, a mechanism revealed by the Ministry of Finance. The group ignored tax obligations and created new tax fraud strategies and mechanisms to avoid paying taxes and harm free competition.

“The proceeds and profits generated by criminal offenses were redistributed in a complex network of intervening persons, especially through holding companies, offshore companies, payment institutions and investment funds. The financial flow of the investigated group is highly organized and sophisticated,” says Cira-SP.

Investigations also demonstrated that strategies to hide and protect the real beneficiaries of fraud were practiced using a network of collaborators. Through various fraudulent actions, lies and institutional and financial layers, they ensure the management and expansion of the business group in the sectors of the fuel production and distribution chain.

According to the authorities, the importers purchased naphtha, hydrocarbons and diesel from abroad with funds from the group’s manufacturers and distributors. Between 2020 and 2025, people surveyed imported about R$32 billion worth of fuel. Companies linked to the group “repeatedly evaded taxes in their operations.”

The money was reinvested in companies, real estate and investment funds. In a memorandum, the tax authority says it has identified 17 funds, with assets amounting to R$8 billion. To make it difficult to determine the financial flows, most of the funds were closed by a single shareholder, who was also an investment fund. In this way, the suspects created “layers of concealment.”

In September, the renewal operation was closed due to irregularities in the procurement and refining of gasoline, as a result of Operation Carbon Chain. The authorities made the decision after identifying a series of violations, such as “suspicion of importation with a false content statement (imported gasoline declared as petroleum derivatives for manufacturing), lack of evidence of the refining process and signs of the use of chemical additives not legally licensed.”