CV

Academic Employment

• King’s College London, Reader in Tax Law (previously Senior Lecturer in Law, Lecturer in Law and Postdoctoral researcher) June 2016 – Present
• University of Birmingham, Lecturer in Law January 2018 – September 2018
• University of Oxford, Doctoral candidate, college lecturer and tutor September 2013-January 2018

Education 

• University of Oxford: D.Phil. (Doctor of Philosophy)
• University College London: LL.M (Master of Laws)
• University College Cork, Ireland: BCL International (Bachelor of Laws)
• Chartered Institute of Taxation (CTA (Fellow))

Books

• Stephen Daly, Comparative tax administration: The Rule of Law in Tax Administration in Germany, the UK and the US (Cambridge University Press, forthcoming 2028)
• Ruth Mason and Stephen Daly, Tax and State aid: After Apple (Oxford University Press, forthcoming 2026)
• Stephen Daly, Tax Authority Advice and The Public (Hart 2020)

Edited Collections

• Stephen Daly (ed.), Democracy and Tax Administration [2024] 2 British Tax Review Special Issue, pp. 179-352

Journal Publications

• Tofigh Hasen Nezhad Nisi, Stephen Daly and Francien Dechesne, ‘Ethics in AI use for tax administration: Guidelines for the future’ (forthcoming, Intertax)
• Ruth Mason and Stephen Daly, ‘What went wrong in the Apple State aid case and how to fix it: Part 2 Suggested Reforms’ (2025) 44(3) Virginia Tax Review 421
• Ruth Mason and Stephen Daly, ‘What went wrong in the Apple State aid case: Part 1 The Case’ (2025) 44(3) Virginia Tax Review 351
• Stephen Daly, ‘Artificial Intelligence, the Rule of Law and Public Administration: the Case of Taxation’ (2024) 83(3) Cambridge Law Journal 437
• Ruth Mason and Stephen Daly, ‘Rotten to the Core: The EU’s Court of Justice Decision in Apple’ (2024) 116(11) Tax Notes International 987
• Stephen Daly, ‘Plus ça change: The fate of the Commission’s open investigations’ (2024) 64(6) European Taxation 241
• Stephen Daly, ‘Debate: The Advocate General’s opinion in Commission v Ireland and Apple’ (2024) 52(6/7) Intertax 493
• Stephen Daly, ‘Editorial: Democracy and Taxation’ [2024] 3 British Tax Review 204
• Stephen Daly, ‘Good guidance: Guidelines for Compliance and LITRG report’ [2023] 4 British Tax Review 377
• Martin Hearson and Stephen Daly, ‘Tax negotiations for Global Britain’ (2023) 34(1) King’s Law Journal 170
• Stephen Daly, ‘Tax systems – adaptability and resilience during a global pandemic’ (2023) 53(5) Accounting and Business Research 531
• Stephen Daly, ‘The OMC, intelligent accountability and monitoring national tax authorities’ (2022) Modern Law Review
• Stephen Daly and Amy Lawton, ‘Another check of the temperature of tax teaching in the UK’ [2022] 2 British Tax Review
• Stephen Daly, Helen Hughson and Glen Loutzenhiser, ‘Valuation for the purposes of a wealth tax’ (2021) 42(3/4) Fiscal Studies 615
• Stephen Daly, ‘The UK’s implementation of ATAD’ (2021) 49(11) Intertax 938
• Stephen Daly, ‘The power to get it wrong’ (2021) Law Quarterly Review 280
• Stephen Daly, ‘The Rule of (Soft) law’ (2021) 32(1) King’s Law Journal
• Ruth Mason and Stephen Daly, ‘State Aid: The General Court Decision in Apple’ (2020) 99(10) Tax Notes International 1317/(2020) 168(10) Tax Notes Federal 1791
• Stephen Daly, ‘Finance Act 2020 notes: section 13: payments to voluntary office-holders’ [2020] 4 British Tax Review 410
• Stephen Daly, ‘The aberrant tort of lawful means conspiracy?’ (2020) 30(1) King’s Law Journal 145
• Stephen Daly, ‘The constitutional implications of an EU arm’s length principle’ (2020) 60(2/3) European Taxation 70
• Ulrike Spangenberg, Ann Mumford and Stephen 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
• Stephen Daly and Joseph Tomlinson, ‘Administrative Inconsistency in the Courts’ (2018) 23(3) Judicial Review 190
• Stephen Daly, ‘Public law in the tax tribunals and the case for reform’ [2018] British Tax Review 94
• Stephen Daly, ‘Tax exceptionalism: a UK perspective’ (2017) 3(1) Journal of Tax Administration 95
• Stephen Daly, ‘The Relationship between Tax Authorities, Large Multinationals and the Public’ (2017) 71(5) Bulletin for International Taxation 243
• Stephen Daly, ‘The Taxing Consequences of Brexit’ (2016) 27(3) King’s Law Journal 463
• Stephen Daly, ‘Oversight of HMRC Soft-Law: Lessons from the Ombudsman’ (2016) 38(3) Journal of Social Welfare and Family Law 343
• Stephen Daly, ‘Recent developments in tax law: vires revisited’ [2016] 2 Public Law 190

Book Chapters

• Stephen 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)
• Alison Jones and Stephen Daly, ‘The “undertaking” and single entity doctrine’ in F. Thépot and A. Tzanaki, Research Handbook on Competition and Corporate Law (Edward Elgar 2025)
• Stephen Daly, ‘The Rule of Law, Accountability and Tax Administration’ in D. De Cogan and P. Harris, Tax, public finance and the rule of law (Hart 2024)
• Alison Jones and Stephen Daly, ‘The “undertaking” and single entity doctrine’ in F. Thépot and A. Tzanaki, Research Handbook on Competition and Corporate Law (Edward Elgar 2024)
• Stephen Daly, ‘United Kingdom’ in Michael Lang et al (eds) The Implementation and Lasting Effects of the Multilateral Instrument (IBFD 2021)
• Stephen Daly, ‘Drawing the boundaries of HMRC’s discretion’ in Rita de la Feria and Glen Loutzenhiser (eds), Essays in Honour of Judith Freedman (Hart 2020)
• Daly, ‘United Kingdom’ in Funda Başaran Yavaşlar and Johanna Hey (eds), Tax Transparency: EATLP International Tax Series Volume 17 (IBFD 2019)
• Stephen Daly, ‘The Life and Times of ESCs: A defence?’ in Dominic de Cogan and Peter Harris (eds), Studies in the History of Tax Law: Volume 8 (Hart 2017)

Case notes

• Stephen Daly, ‘Commission v Luxembourg and Engie – (another?) mortal wound in the Commission’s campaign’ [2024] 1 British Tax Review 91
• Stephen Daly, ‘A positive concession? Murphy v HMRC [2023] EWCA Civ 497’ [2023] 4 British Tax Review 515
• Stephen Daly, ‘Fiat v Commission: a misconceived approach’ [2023] 86(6) Modern Law Review 1489
• Stephen Daly, ‘Tinkler v Revenue and Customs: a complicated mistake?’ [2021] 5 British Tax Review 558
• Stephen Daly, ‘Legality, interpretation and access to justice: Beadle v HMRC’ [2020] British Tax Review 567
• Stephen Daly, ‘Scott v HMRC: Principles, policies and interpretation’ [2018] 4 British Tax Review 381
• Stephen Daly, ‘Legitimate Expectations and HMRC Advice’ (2018) 77(2) Cambridge Law Journal 265
• Stephen Daly, ‘Public disclosures and HMRC’s duty of confidentiality: R (Ingenious Media) v HMRC’ [2017] 1 British Tax Review 10
• Stephen Daly, ‘Fairness in tax law and revenue guidance: R (Hely-Hutchinson) v HMRC’ [2016] 1 British Tax Review 18

Book reviews:

• Stephen Daly, ‘Tax Law and Digitization: How to Combine Legal Tech and Tax Tech, by Michael Lang and Robert Risse (eds) (Wolters Kluwer, 2021)’ [2024] British Tax Review 171
• Stephen Daly, ‘Tax Procedure, by P. Pistone (ed) (IBFD, 2020)’ [2023] 2 British Tax Review 239
• Stephen Daly, ‘A Research Agenda for Tax Law, by L. Parada (ed) (Edward Elgar, 2022)’ [2022] 5 British Tax Review 607
• Stephen Daly, ‘Tax Justice and Tax Law, by D. de Cogan and P. Harris (eds) (Hart Publishing, 2020)’ [2022] 2 British Tax Review 232
• Stephen Daly, ‘Ethics and Taxation, by R. van Brederode (ed) (Springer Publishing, 2020)’ [2020] 3 British Tax Review 381
• Stephen Daly, ‘Guide to Taxpayers’ Rights and HMRC Powers, by R. Maas (6th edn., Bloomsbury Professional, 2018)’ [2020] 3 British Tax Review 385
• Stephen Daly, ‘Selectivity in State Aid Law and the Methods for the Allocation of the Corporate Tax Base, by J. Monsenego (Kluwer Law International, 2018)’ [2020] 1 British Tax Review 132

Reports

• Stephen Daly and Heather Self, Large Business Tax Disputes (Report for the IFS Tax Law Review Committee, 2023)
• Stephen Daly and Glen Loutzenhiser, ‘Valuation’ (Report for IFS Wealth Tax Project, 30 October 2020)
• Stephen Daly, ‘Tax Transparency’ (Report for EATLP, 15 November 2017)
• Ulrike Spangenberg, Ann Mumford, Stephen Daly, ‘Navigating taxation towards sustainability: Contradictions between Social, Gender, Environmental, and Economic ambitions, obligations and governance capacities in European tax law’ (Report for European Commission, 31 August 2017)

Parliamentary submissions

• Submission to Treasury Sub-Committee Conduct of Tax Enquiries and the Resolution of Tax Disputes inquiry
• Submission to The House of Lords Economic Affairs Committee’s Finance Bill Sub-Committee Draft Finance Bill 2018 Call for evidence

Other Publications

• Failing to sense the mood music: the AG’s opinion in Commission v Ireland and Apple (2024) 1646 Tax Journal 20
• Resolving large business tax disputes: what more should be done? (2023) 1634 Tax Journal 18
• VAT Interest and Penalties: Digging through the data (2023) Tax Journal
• Guidelines for Compliance (2023) 5 Tax Point 6 (with Katarina Lau and Dasha Nastasiy)
• The CJEU’s ruling in the FIAT state aid case (2022) 1597 Tax Journal 6
• COVID Schemes: Fraud and Abuse (April 2022) Tax Point 8
• ‘The state aid decision in Apple’ (2020) 1497 Tax Journal 6
• ‘The doctrine of legitimate expectations in Aozora: Normative underpinnings and the public interest in tax collection’ (2019) 1462 Tax Journal 6
• ‘Hely-Hutchinson and legitimate expectation’ (2019) 1440 Tax Journal
• ‘The OTS Strategic Review’ (2018) 1418 Tax Journal 15
• ‘The language of avoidance cases’ (2017) 1366 Tax Journal 8
• ‘When HMRC changes its advice’ (2017) Accountingweb.co.uk
• ‘Yet another case concerning APNs’ (2017) 1362 Tax Journal
• ‘Vrang: UK/Swiss tax cooperation’ (2017) 1355 Tax Journal 6
• “We’ve got Google to pay taxes”: Famous Last Words for Independence (Guest-blog, 2016)
• Tax, Morality and Reality (Guest blogpost, 2014)
• Musings on our Shared History (Letters, Cork Online Law Review 2014)
• Flights to New York from £200 Return: Analysis of the Aer Lingus/Ryanair Merger (Pi Magazine, UCL 2013)
• Oversights of the Personal Insolvency Legislation (Letters, Cork Online Law Review 2013)
• Avoiding Tax: Harry Redknapp and the Romanian Witches (Letters, Cork Online Law Review 2013)

Media citations/appearances

• Ruth Mason and Stephen Daly, Apple victory would do nothing to discipline giant over tax deal, The Times (London: 21 March 2024)
• Stephanie Soong, Fugro Appeals EU General Court’s Dismissal of Pillar 2 Challenge (11 March 2024) Tax Notes Today International
• Philip Fisher, Billions in tax revenues going to waste, Accountingweb (22 February 2024)
• Edward Siddons and Jon Ungoed-Thomas, HMRC investigations of wealthy ‘tax dodgers’ halve in five years, The Observer (London, 18 February 2024)
• Todd Buell, “Vestager’s EU Tenure Shaped International Tax Despite Court Losses”, Law360 (Brussels, 19 October 2023)
• Ryan Finley, “Will Amazon Appeal Clarify Burden of Proof in State Aid Cases?” (13 June 2022) Tax Notes Today International
• Todd Buell, “State Aid Law No Obstacle To Irish Two-Tier Tax”, Law360 (Brussels, 14 October 2021), available at: https://www.law360.com/tax-authority/articles/1431046
• Amy Lawton and David Massey, “Help improve HMRC’s guidance” (2021) 187(4787) Taxation 8, available at: https://www.taxation.co.uk/articles/-help-improve-hmrc-s-guidance
• Ryan Finley and Kiarra Strocko, “Amazon and Engie Cast Doubt on State Aid Enforcement Approach”, Tax Notes Today International (14 May 2021)
• Simon Van Dorpe, “Vestager’s campaign against controversial tax deals reaches final stage”, Politico (Brussels, 9 May 2021), available at: https://www.politico.eu/article/vestager-illegal-state-aid-tax-deal-ecj-eu-europe-fiat-luxembourg/
• Simon Van Dorpe, “Vestager doubles down in €13B Apple legal battle”, Politico (Brussels, 25 September 2020)
• Simon Van Dorpe, “Vestager faces risks in potential appeal of Apple ruling”, Politico (Brussels, 23 September 2020), available at: https://www.politico.eu/article/margrethe-vestager-potential-appeal-apple-ruling/
• Tax Notes podcast, “iWin: A Closer Look at Apple’s State Aid Victory” (6 August 2020), available at: https://www.taxnotes.com/tax-notes-talk/podcast/iwin-closer-look-apples-state-aid-victory/2ct8g
• Ryan Finley, “Will the EU Commission Cut Its Losses After the Apple Decision?”, Tax Notes Today International (30 July 2020), available at: https://www.taxnotes.com/tax-notes-today-international/transfer-pricing/will-eu-commission-cut-its-losses-after-apple-decision/2020/07/30/2crzr
• Isabel Gottlieb and Hamza Ali, “EU Appeal of $15 Billion Apple Tax Case Faces Uphill Battle”, Bloomberg Tax (22 July 2020), available at: https://news.bloombergtax.com/daily-tax-report-international/eu-appeal-of-15-billion-apple-tax-case-faces-uphill-battle
• Hamza Ali, “‘Take Action Now,’ U.K. Tells Tech Companies in Tax Guidance”, Bloomberg Tax (1 April 2020), available at: https://news.bloombergtax.com/daily-tax-report-international/take-action-now-u-k-tells-companies-in-new-tech-tax-guidance
• “European Court Upholds Belgium’s Tax Breaks for Multinationals”, taxlinked.net (15 February 2019), available at: https://taxlinked.net/blog/february-2019/european-court-upholds-belgiums-tax-breaks-multinationals
• John Stokdyk, “HMRC wins accelerated payment judicial review”, accountingweb (24 March 2016), available at: https://www.accountingweb.co.uk/tax/hmrc-policy/hmrc-wins-accelerated-payment-judicial-review

Invited Talks

• The €13bn question: is the fiscal State aid era over? (tax@univie, April 2024)
• Principles and standards (AI, Tax and Fintech Conference: University of Surrey, June 2023)
• The Civic Function of Taxation (Research Forum in Tax Law: University of Oslo, May 2023)
• The Civic Function of Taxation (Tax Law and Policy Discussion Group: University of Oxford, 2023)
• Tax systems – adaptability and resilience during a global pandemic (ICAEW IFBM Annual Conference: London, December 2022)
• Innovation and tax education (Keynote) (TRN Annual Conference: Edinburgh, September 2022)
• The future of UK tax in a post COVID-19 world (CIOT Autumn Virtual Conference 2020: September 2020)
• Reliance on HMRC guidance (VAT Practitioners Group Annual Conference: Hertford, June 2019)
• Drawing the boundaries of HMRC’s discretion and the allocation of resources in tax collection (Max Planck Institute Research Seminar, Munich, April 2019)
• The taxation of GAFA (Aix-Marseille University Conference, March 2019)
• Brexit and tax: the last word (9th International tax conference, King’s College London, March 2019)
• Blogging and education (University of Nottingham: Nottingham, December 2018)
• HMRC Guidance…what is it good for? (VAT Practitioners Group Annual Lecture: London, September 2018)
• Tax, Mergers and Acquisitions: Haim Striks Immersive M&A course (Oxford, August 2018)
• Brexit and Tax Administration (University of Exeter and IFS joint roundtable: London, March 2017)
• Trends in Tax Exceptionalism and Tax Litigation (Journal of Tax Administration and Cambridge Centre for Tax Law Conference: London, July 2016)
• HMRC Soft-Law: the suitability of an Australian type rulings system in the UK (University of New South Wales, March 2016)

Conferences and Presentations

• Artificial Intelligence, the Rule of Law and Public Administration (Diplomatic Academy of Vienna, 17 April 2024)
• Artificial Intelligence, the Rule of Law and Public Administration (WU Vienna Department of Tax Law, 17 April 2024)
• UK Tax Policy – possible options to stimulate economic growth (Young IFA Corporate Tax Practitioners conference, 21 September 2023)
• The Rule of Law, Access to Justice and Tax Administration (Cambridge Tax Policy Conference, University of Cambridge, 3-4 July 2023)
• Panel discussion on the Fiat, Ireland and Luxembourg v Commission Judgment (KCL Rapid Response Seminar, 8 December 2022) (Organiser)
• Tax in a post-COVID world (Young IFA Corporate Tax Practitioners conference, 22 September 2022)
• The Civic Function of Tax (SLS Annual Conference: King’s College London, September 2022)
• Trust, Tax Administration and State Aid (Global Tax Symposium: Leiden University, 8 December 2021)
• Trust, Tax Administration and State Aid (University of Vienna, 7 October 2021)
• (w/ Amy Lawton) Mapping Tax Education in the UK (TRN Annual Conference: Aston University, 10 September 2021)
• Tax Certainty: The role of guidance and advice (IFA UK Webinar Series, 19 May 2021)
• (w/ Glen Loutzenhiser, Elizabeth Mann and Helen Hughson) A Wealth Tax for the UK? Assessing Valuation and Liquidity Issues (Tax Law & Policy DG: Oxford, February 2021)
• Priority-setting in tax administration (8^th Annual TARC Workshop: Exeter University, December 2020)
• Administrative Law and Tax Administration (Administrative Law Scholarship & Doctrinal Realities: Are Our Intellectual Frameworks Fit for Purpose? Corpus Christi College, Oxford, October 2020)
• Should retrospective taxation be permitted (London Tax Network debate, September 2020)
• (w/Glen Loutzenhiser) Valuation issues (Wealth Tax Workshop: LSE Inequalities Institute, September 2020)
• Legality and desirability of getting it wrong (TARC Workshop Improving the Resolution of Tax Disputes, August 2020)
• Trust, Tax Administration and State aid (Indiana/Leeds Summer Tax Workshop Series, May 2020)
• The power to get it wrong in State aid law (Max Planck European Postdoctoral Conference on Tax Law, Munich, November 2019)
• Understanding Brexit: the constitution, law and politics (Centre for Transnational Legal Studies, London, October 2019)
• Priority-setting in tax administration (SLS Annual Conference: Preston, September 2019)
• Tax in the Digital Age: Short Term Solutions (New Trends in Common Law: IALS London, September 2019)
• The virtues of tax authority advice (4^th International Conference on Taxpayer Rights, Minnesota, May 2019)
• Drawing the boundaries of HMRC’s discretion (Conference in honour of Judith Freedman, Oxford, May 2019)
• The “puzzling” tort of lawful means conspiracy (King’s Private Law Forum, King’s College London, December 2018)
• Legal blogs in tax education (TRN Annual Conference: Birmingham, September 2018)
• Tax Rulings in Troubled Times (SLS Annual Conference: London, September 2018)
• Tax, Mergers and Acquisitions: Haim Striks Immersive M&A course (Oxford, August 2018)
• The right of tax authorities to get it wrong and the implications for the Commission’s State Aid investigations (Oxford – Sydney Tax Research Conference, June 2018)
• Identifying the Frontiers of Public Law Principles: Soft Law and the Normal Justification Thesis (3nd Biannual Public Law Conference: Melbourne, July 2018) (w/P. Daly) [accepted but not presented]
• Form and substance in the law of torts: explaining the “puzzling” tort of lawful means conspiracy (Obligations Conference: Melbourne, July 2018) [accepted but not presented]
• HMRC as tax advisor – types 1 & 2 soft law and protections in tax (5th Annual TARC Workshop: Exeter University, April 2018)
• Soft law – type 1, type 2 and protections in tax (SLSA Conference: Bristol, April 2018)
• Mapping public law on to tax law- the EU Commission, rulings and a prior question of deference (SLS Annual Conference: Dublin, September 2017)
• Unity in torts through understanding competition law (SLS Annual Conference: Dublin, September 2017)
• Early career researchers roundtable on administrative justice (University of Sheffield, September 2017)
• Holding HMRC to account through the tribunals (4th Annual TARC Workshop: Exeter University, April 2017)
• Holding HMRC to account through the tribunals (SLSA Conference: Newcastle, April 2017)
• The Unity of Public Law: Tax Exceptionalism (2nd Cambridge Biannual Public Law Conference, September 2016)
• The (Biased) Role of the Judiciary in Tax Law Reviews (SLS Annual Conference: Oxford, September 2016)
• ESCs: From the Glorious Revolution to Wilkinson (Tax Law History Conference VIII: Cambridge, June 2016)
• Judicial Review and Tax Exceptionalism (Tax Policy Conference 2016: Cambridge, April 2016)
• Oversight of HMRC soft-law: lessons from the Ombudsman? (SLSA Conference: Lancaster, April 2016)
• The control of public power: the need for systemic reform of HMRC soft-law (CJICL Conference: Cambridge, April 2016)
• The Life and Times of ESCs: a Defence? (OUCBT Doctoral Meeting, September 2015
• ESCs: the next step? (Durham University PGR Conference, June 2015)
• The Relationship between Tax Authorities, Large Multinationals and the Public (IBFD Doctoral Conference: Amsterdam, May 2015)
• Recent Developments in Tax Law on the Doctrine of Ultra Vires (SLSA Conference: Warwick, March 2015)
• Legitimate Expectations in Tax Law (Tax Law & Policy DG: Oxford, March 2015)
• Concessions and Expectations (CBT Seminar: Oxford, February 2015)
• APAs and Settlements: Musings on our Shared History (Trinity Law Colloquium: TCD, February 2015)
• An Investigation of Revenue Discretion: Difficulties with a fictitious divide (CLRM Conference: Oxford, May 2014)

Associations

• Member of the European Association of Tax Law Professors
• Member of HMRC Guidance Strategy Forum
• Managing editor (law) at Journal of Tax Administration
• Book review and reports editor at the British Tax Review
• Member of the IFS Tax Law Review Committee
• Freeman of the Worshipful Company of Tax Advisers
• Associate Member of the European Association of Tax Law Professors
• Associate Fellow of the Higher Education Academy
• Member of the Society of Legal Scholars and co-convenor of the tax stream