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54(1)A person is also guilty of an offence (subject to sub-paragraph (2)) if the person conceals, destroys or otherwise disposes of, or arranges for the concealment, destruction or disposal of a document after the person has been informed by an officer of Revenue and Customs in writing that—
(a)the document is, or is likely, to be the subject of an information notice addressed to that person, and
(b)an officer of Revenue and Customs intends to seek the approval of the First-tier Tribunal to the giving of the notice under paragraph 3 or 5 in respect of the document.
(2)A person is not guilty of an offence under this paragraph if the person acts after—
(a)at least 6 months has expired since the person was, or was last, so informed, or
(b)an information notice has been given to the person requiring the document to be produced.
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