In a change of understanding, the 1st Panel of the CARF Superior Chamber maintained a qualified fine in the case of omission of revenue, according to the understanding that there was fraud on the part of the taxpayer, who did not declare the full amount of revenue earned.
It is worth mentioning that the qualified fine is applied in cases where intent, fraud or simulation is established, in which the percentage of the fine imposed increases from 75% to 150%, on the full amount due to the tax authorities.
