A Reader in Tax law at King’s College London, Dr Stephen Daly studies what tax law, policy and administration can do in a society committed to the Rule of Law, fairness and democracy. He has published over 40 papers in leading generalist law journals (Cambridge Law Journal, Law Quarterly Review, Modern Law Review), specialist tax journals (British Tax Review, Bulletin for International Taxation, European Taxation, Fiscal Studies, Intertax, Virginia Tax Review) and various edited collections. His first sole-authored, award-winning monograph Tax Authority Advice and the Public (2020) on the Rule of Law implications of HMRC giving advice to taxpayers has been described as ‘important’ (Dr Giorgio Beretta, Amsterdam); ‘a fine monograph’ (Professor Hans Gribnau, Tilburg); ‘excellent’ (Professor Steven Vaughan, Monash); and ‘a point of reference’ (Professor Dominic de Cogan, Cambridge). His commentary on issues of tax law and policy has featured in The Business Post, The Irish Examiner, The Irish Times, The Observer, The Times, specialist law and tax media (Bloomberg Tax, Tax Journal, Tax Notes Today International, Politico, Law360) as well as on the BBC World Service.
Stephen holds degrees in law from University College Cork (BCL, graduating top of the class), University College London (LLM, graduating top of his class) and the University of Oxford (DPhil). He also became a CTA (Fellow) in 2023, for which he received the Fellowship Medal (the first awarded since 2015). After completing his doctoral studies and several years of teaching at the University of Oxford, Dr Daly joined King’s College London where he was first a postdoctoral researcher (2016), before becoming a (tenured) Lecturer (2018), Senior Lecturer (2021) and Reader (2024). He was previously a Lecturer in Law at the University of Birmingham.
In 2026, he became the youngest ever sole General Editor of the British Tax Review, a world leading tax law journal. He is also a member of HMRC’s Guidance Strategy Forum and the Tax Law Review Committee of the Institute for Fiscal Studies.
At King’s College London he is Associate Dean (Research). He has previously served as Senior Tutor, Director of Mooting and Widening Participation Lead.
Research interests
Artificial intelligence and tax administration
Pollyanna tells us AI brings efficiency and effectiveness. Cassandra tells us it threatens democracy. Neither are inexorable or pre-determined. In Stephen’s work on AI and tax administration, he has sought to articulate how AI ought to be regulated as well as how it can advance the Rule of Law, foster trust and further democratic legitimacy.
Selected publications:
- Daly, ‘United Kingdom’ in G. Kofler, M. Lang, P. Pistone, A. Rust, J. Schuch, K. Spies, C. Staringer, R. Stern and R. Szudoczky (eds), The Impact of Artificial Intelligence on Tax Law (IBFD 2026)
- Daly, ‘Trustworthy AI and HMRC’ [2026] 2 British Tax Review 161
- Hasen Nezhad Nisi, S. Daly and F. Dechesne, ‘Ethics in AI use for tax administration: Guidelines for the future’ (2025) 53(11) Intertax 724
- Daly, ‘Artificial Intelligence, the Rule of Law and Public Administration: the Case of Taxation’ (2024) 83(3) Cambridge Law Journal 437
- Daly, ‘Taxing Better: Using AI to Advance Democracy’ (Report supported by British Academy and Leverhulme Trust, 2025)
The Rule of Law in taxation
Taxes are imposed by law and so fidelity to the Rule of Law should be paramount. But what does it mean? And what do its demands mean for the scope of tax authority powers and the rights of taxpayers? These are some of the issues Stephen has tackled in his writings on the Rule of Law in taxation.Selected publications:
- Daly, Comparative Tax Administration (Cambridge University Press, forthcoming)
- Daly, ‘The Rule of Law: a Common Principle with Different Manifestations’ in Pasquale Pistone (ed), The Common Constitutional Tradition of the European Union and Its Impact on Tax Law (IBFD 2026)
- Daly, ‘The Rule of Law, Accountability and Tax Administration’ in D. De Cogan, A. Brassey and M. Hen, Tax, public finance and the rule of law (Hart 2025)
- Daly, ‘Artificial Intelligence, the Rule of Law and Public Administration: the Case of Taxation’ (2024) 83(3) Cambridge Law Journal 437
- Daly, ‘The Rule of (Soft) law’ (2021) 32(1) King’s Law Journal
- Daly, Tax Authority Advice and the Public (Hart 2020)
- Daly, ‘Public law in the tax tribunals and the case for reform’ [2018] British Tax Review 94
- Daly, ‘Oversight of HMRC Soft-Law: Lessons from the Ombudsman’ (2016) 38(3) Journal of Social Welfare and Family Law 343
Taxation and State aid law (anti-subsidy rules)
Multinationals must pay the taxes that are due under the law. But politicians (and administrators) are liable to favour them through their laws and administration in return for promises of investment, continued presence in the jurisdiction and contributions to the public purse. Anti-subsidy rules, known as ‘State aid’ rules in the EU, regulate that temptation. What the purpose of those rules should be and how they interact with tax law and administration are issues that Stephen addresses in his work.
Selected publications:
- Mason and S. Daly, Tax and State aid: After Apple (Oxford University Press, forthcoming)
- Mason and S. Daly, ‘What went wrong in the Apple State aid case’ (2025) 44(3) Virginia Tax Review 351 (Part 1); 421 (Part 2)
- Mason and S. Daly, ‘Rotten to the Core: The EU’s Court of Justice Decision in Apple’ (2024) 116(11) Tax Notes International 987
- Daly, ‘Plus ça change: The fate of the Commission’s open investigations’ (2024) 64(6) European Taxation 241
- Daly, ‘Debate: The Advocate General’s opinion in Commission v Ireland and Apple’ (2024) 52(6/7) Intertax 493
- Daly, ‘United Kingdom and ITV Plc v European Commission: comparing apples with apples?’ [2024] 5 British Tax Review 725
- Daly, ‘Commission v Luxembourg and Engie – (another?) mortal wound in the Commission’s campaign’ [2024] 1 British Tax Review 91
- Daly, ‘Fiat v Commission: a misconceived approach’ [2023] 86(6) Modern Law Review 1489
- Daly, ‘The OMC, intelligent accountability and monitoring national tax authorities’ (2022) 85(5) Modern Law Review 1109
- Daly, ‘The power to get it wrong’ (2021) Law Quarterly Review 280
- Mason and S. Daly, ‘State Aid: The General Court Decision in Apple’ (2020) 99(10) Tax Notes International 1317/(2020) 168(10) Tax Notes Federal 1791
- Daly, ‘The constitutional implications of an EU arm’s length principle’ (2020) 60(2/3) European Taxation 70
The role of taxation in society
Stephen’s research also considers the role that taxation plays in society, with his work investigating how tax law can be interpreted to promote values such as sustainability, how tricky problems of valuation can be overcome so that wealth taxes can be levied, how the tax system can be engineered to implement fiscal, health and social policy, and how tax is taught in universities.
Selected publications:
- Daly, ‘Tax systems – adaptability and resilience during a global pandemic’ (2023) 53(5) Accounting and Business Research 531
- Daly and A. Lawton, ‘Another check of the temperature of tax teaching in the UK’ [2022] 2 British Tax Review 202
- Daly, H. Hughson and G. Loutzenhiser, ‘Valuation for the purposes of a wealth tax’ (2021) 42(3/4) Fiscal Studies 615
- Spangenberg, A. Mumford and S. Daly, ‘Moving beyond the narrow lens of taxation: The Sustainable Development Goals as an Opportunity for Fair and Sustainable Taxation’ (2019) 26(1) Columbia Journal of European Law 36

