Author Archives: Dr Stephen Daly

In the past few months, I have been busy pulling together my notes on the Commission’s tax ruling campaign – its litigation against Ireland, Luxembourg and the Netherlands in respect of rulings granted to Apple, Engie, Fiat and Amazon, and … Continue reading →

Since time immemorial it has been accepted that taxpayers with a close connection with a jurisdiction should pay tax on their income in that jurisdiction. This norm informs the taxing rights of countries – literally, their right to impose tax. … Continue reading →

Dickson Poon School of Law, Somerset House East Wing, Strand, London WC2R 2LS Friday 8 September 2023 Registration 9am-9.20am (Wellington Room) Introduction 9.20am-9.30am (Moot Court) Dr Stephen Daly (King’s College London)   Morning Session: 9.30am – 10.00am (Moot Court) Francesco … Continue reading →

The ECJ handed down a highly significant judgment today in the case of Fiat and Luxembourg v Commission concerning the application of the EU State aid rules to tax rulings. The case concerned a 2012 tax ruling provided to Fiat … Continue reading →

Where a tax authority fails to collect taxes due, who holds them to account? The answer, at a domestic level, will depend on the jurisdiction but may be the courts, Parliament, the media, specialist committees and so on. But there … Continue reading →

The recent Supreme Court case of Tinkler v HMRC [2021] UKSC 39 dealt with the consequences of an administrative error. A notice of enquiry was not sent to the correct address. This is problematic because the statutory provision requires that … Continue reading →

In recent years, the UK has been tasked with implementing various tax rules which have been negotiated and agreed at the international level, albeit in very different circumstances, namely the EU Anti-Tax Avoidance Directive (ATAD) and the OECD led Multilateral … Continue reading →

One of the issues often raised with plans to introduce is wealth tax is the problem of valuation. Aside from political issues around the tax base, and assuming that value should be determined by reference to market value, how does … Continue reading →