Is it reasonable, or covered by the DPA / GDPR, to request a copy of all files held by a previous Accountant ?
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No.
GDPR covers processing of personal data.
Very little of the data contained in "all files" is likely to be your personal data and so would not be covered by a Subject Access Request (SAR).
I think it's a reasonable question. But it would also be reasonable for your accountant to charge for the time involved. What happened to the retired accountant's practice - and more importantly, what happened to the records?
The difference between the total expenses per your records and the expenses on your tax return *may* be due to personal or other expenses that your accountant disallowed.
Whether it is wise to field an HMRC investigation yourself is a different question. If you are having difficulty in responding to their questions in the time allotted, do go back to them and request an extension. In my very limited experience, HMRC are reasonable about giving extra time as long as you discuss before the due date.
Not responding is somewhat different from refusing to co-operate. I don't think there is any legal obligation on your accountant. In strict terms, it's your tax return and you should understand and approve the submission.
I'd pick up the phone rather than rely on email. It's much harder to ignore.
And, as previously advised, I'd call HMRC before their deadline and request an extension.
I'd pick up the phone rather than rely on email. It's much harder to ignore.
And write them a letter...