Where CDF offer is made up to 29 June 2014: managing the detailed disclosure process: request for access to accountant’s link papers
When you are discussing/considering the business side of matters, the taxpayer should be asked if they are willing for the accountant to co-operate with HMRC by providing full access to all their link papers and working papers. For example, any papers that reconcile the figures appearing in the business books and records with those in the final accounts and returns submitted to HMRC. If so, the accountant should be asked whether they are willing to make the relevant link papers available. If they are not prepared to do so, then you should ask them why they will not do so and record their response.
It is reasonable to ask for the taxpayer and accountant to undertake that the link papers will be made fully available to HMRC on submission of the disclosure report or during the period that the report is being completed if required.