Exhibit 8.1


                      [LETTERHEAD OF MAYER, BROWN & PLATT]

                                                                April 18, 1997

                                  Tevecap S.A.
                  US$250,000,000 12 5/8% Senior Notes due 2004
                                 Exchange Offer

Ladies and Gentlemen:

      We have acted as United States counsel for (i) Tevecap S.A., a 
Brazilian corporation (the "Company"), and (ii) TVA Sistema de Televisao 
S.A., TVA Communications, Ltd., Galaxy Brasil S.A., TVA Sul Participacoes 
S.A., Commercial Cabo TV Sao Paulo Ltda., TVA Parana Ltda., TVA Alpha Cabo 
Ltda., CCS Camboriu Cable Systems de Telecommunicacoes Ltda., TCC TVA Cabo 
Ltda., TVA Sul Santa Catarina Ltda. and TVA Foz do Iguacu Ltda. 
(collectively, the "Subsidiary Guarantors"), in connection with the filing by 
the Company and the Subsidiary Guarantors with the Securities and Exchange 
Commission (the "Commission") of a registration statement (the "Registration 
Statement") on Form F-4 under the Securities Act of 1933, as amended, 
relating to the proposed issuance, in exchange for US$250,000,000 aggregate 
principal amount of the Company's 12 5/8% Senior Notes due 2004 (the "Old 
Notes"), jointly and severally guaranteed by the Subsidiary Guarantors, of 
US$250,000,000 aggregate principal amount of the Company's 12 5/8% Senior 
Notes due 2004 (the "Exchange Notes"), jointly and severally guaranteed by 
the Subsidiary Guarantors. The Exchange Notes are to be issued pursuant to an 
indenture dated as of November 26, 1996 (the "Indenture"), among the Company, 
the Subsidiary Guarantors, The Chase Manhattan Bank, N.A., as trustee, and 
Chase Trust Bank, as principal paying agent. Capitalized terms used herein 
and not otherwise defined herein have the meanings ascribed thereto in the 
Indenture.

      We hereby confirm that the statements set forth in the prospectus (the
"Prospectus") forming a part of the Registration Statement under the subheading
"United States" to the heading "Income Tax Considerations" accurately describe
the material Federal income tax consequences to holders of the Exchange Notes
issued pursuant to the Indenture.



      We know that we are referred to under the heading "Legal Matters" in the
Prospectus, and we hereby consent to such use of our name therein and to the use
of this opinion for filing with the Registration Statement as Exhibit 8.1
thereto.

                                Very truly yours,


                                 /s/ MAYER, BROWN & PLATT
                                -------------------------

Tevecap, S.A.
TVA Sistema de Televisao S.A.
TVA Communications, Ltd.
Galaxy Brasil S.A.
TVA Sul Participacoes S.A.
Commercial Cabo TV Sao Paulo Ltda.
TVA Parana Ltda.
TVA Alpha Cabo Ltda.
CCS Camboriu Cable Systems de Telecommunicacoes Ltda. 
TCC TVA Cabo Ltda.
TVA Sul Santa Catarina Ltda.
TVA Foz do Iguacu Ltda.