While this is true for most magic in Perl, not all "magic" is implemented via magic variables. The docs list at least the following areas as "magic", which according to your "strict" definition aren't:
Auto-increment (and range) operator on strings "has a little extra builtin magic to it"
one and two argument open() is called "magic open"
goto &NAME is said to be "highly magical"
So, as usual with Perl, things are a little more fuzzy.
Update: This was supposed to be a reply to Elians comment, not to pgs.