In the context of penal fiscal law there has been a discussion over a proper reaction to a fiscal tort. This is even more important in connection with the increase of the number of criminal offences, particularly in terms of tax offences and the decrease in effectiveness of administrative proceedings of public levies1 . Beyond doubt, the proposals tabled in the discussions aim at objective settlements. This paper comprises an attempt to answer the question of how the justice is perceived in the context of penal fiscal law.