Stephen Daly

King's College London - The Dickson Poon School of Law

Somerset House East Wing

Strand

London, WC2R 2LS

United Kingdom

  • King's College London - The Dickson Poon School of Law

SCHOLARLY PAPERS

31

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Scholarly Papers (31)

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1.

State Aid: The General Court Decision in Apple

99 Tax Notes Int'l 1317 (2020) [also published as 168 Tax Notes Federal 1791 (2020)], Virginia Public Law and Legal Theory Research Paper No. 2020-71, Virginia Law and Economics Research Paper No. 2020-17, King's College London Law School Research Paper No. 2020-46
Number of pages: 19 Posted: 21 Oct 2020 Last Revised: 12 Dec 2020
Stephen Daly and Ruth Mason
King's College London - The Dickson Poon School of Law and University of Virginia School of Law
Downloads 1,088 (39,914)
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State Aid, EU, Tax, Transfer Pricing, Apple, arm's length

2.

The Undertaking and Single Economic Entity Concepts in EU and UK Competition Law: Proposals for a Refined Approach

F. Thepot and A. Tzanaki (eds), Research Handbook on Competition and Corporate Law, Edward Elgar, Forthcoming
Number of pages: 23 Posted: 03 May 2023 Last Revised: 15 Jul 2024
Alison Jones and Stephen Daly
King's College London – The Dickson Poon School of Law and King's College London - The Dickson Poon School of Law
Downloads 867 (54,806)

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Undertaking, single economic entity, single economic unit, personal responsibility, limited liability, piercing the corporate veil

3.

The Taxing Consequences of Brexit

(2016) 27(3) King's Law Journal 463-472
Number of pages: 8 Posted: 19 Oct 2016 Last Revised: 22 May 2017
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 302 (195,561)

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EU Law; Tax Law; Public Law

4.

The Rule of (Soft) Law

(Forthcoming 2021) King's Law Journal, King's College London Law School Research Paper Forthcoming
Number of pages: 10 Posted: 03 Dec 2020 Last Revised: 02 Feb 2021
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 219 (269,124)

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Soft Law; Administrative Law; Rule of Law

5.

UK National Report: EATLP Annual Congress 2018 on Tax Transparency

Number of pages: 18 Posted: 20 Nov 2017 Last Revised: 10 Jul 2018
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 196 (298,113)
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Taxpayer Privacy, Confidentiality

6.

Tax Exceptionalism: A UK Perspective

3(1) Journal of Tax Administration 95, King's College London Law School Research Paper No. 2017-31
Number of pages: 15 Posted: 24 May 2017 Last Revised: 07 Aug 2017
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 182 (318,709)
Citation 1

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Tax, Public Law, Tax Administration, Exceptionalism

7.

'R. (Hely-Hutchinson) v HMRC: Fairness in Tax Law and Revenue Guidance

(2016) British Tax Review 18
Number of pages: 11 Posted: 13 Mar 2016 Last Revised: 08 Mar 2017
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 157 (362,260)

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Tax Law, Public Law, Judicial Review, Legitimate Expectations

8.

Recent Developments in Tax Law: Vires Revisited

(2016) 2 Public Law 190-198
Number of pages: 9 Posted: 27 Apr 2016
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 144 (388,716)

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HMRC powers, Legitimate expectation, Ultra vires

9.

R. (Ingenious Media) v HMRC: Public Disclosures and HMRC's Duty of Confidentiality

(2017) 1 British Tax Review 10, King's College London Law School Research Paper No. 2017-25
Number of pages: 14 Posted: 10 Mar 2017 Last Revised: 09 Jun 2017
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 132 (416,220)

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Judicial Review, Tax Law, Public Law, Confidentiality

10.

Legitimate Expectations and HMRC Advice

(2018) 77(2) Cambridge Law Journal 265
Number of pages: 3 Posted: 21 Dec 2017 Last Revised: 11 Jul 2018
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 115 (462,165)

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Tax, Public Law, Legitimate Expectations

11.

Tax Authority Advice and the Public

Stephen Daly, Tax Authority Advice and the Public, Hart Publishing, 2020
Number of pages: 34 Posted: 18 May 2020
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 113 (468,295)

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Tax Law, Public Law, Tax Administration

12.

Another Check of the Temperature of Tax Teaching in the UK

(2022) 2 British Tax Review 202
Number of pages: 29 Posted: 13 Jul 2022
Stephen Daly and Amy Lawton
King's College London - The Dickson Poon School of Law and University of Edinburgh, Edinburgh Law School
Downloads 104 (497,323)

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Tax Law, Higher Education, Teaching

13.

The Aberrant Tort of Lawful Means Conspiracy

31(1) King's Law Journal, 2020
Number of pages: 24 Posted: 14 May 2020
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 101 (507,598)

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Tort, Conspiracy, Competition Law

14.

Public Law in the Tax Tribunals and the Case for Reform

(2018) 1 British Tax Review 94
Number of pages: 20 Posted: 28 Dec 2017 Last Revised: 13 May 2018
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 94 (532,204)

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public law, tax, tribunals

15.

The Life and Times of ESCs: A Defence?

Stephen Daly, 'The Life and Times of ESCs: A defence?' in 'P. Harris and D. de Cogan (eds), Studies in the History of Tax Law: Volume 8 (Hart 2017), King's College London Law School Research Paper No. 2017-36
Number of pages: 38 Posted: 15 May 2017 Last Revised: 22 May 2018
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 84 (570,491)

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Tax History, Extra-statutory concessions, Administrative Discretion

16.

Scott v HMRC: Principles, Policies and Interpretation

(2018) 4 British Tax Review 381, King's College London Law School Research Paper No. 19-7
Number of pages: 7 Posted: 01 Nov 2018
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 83 (574,597)

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Tax, Statutory Interpretation

17.

The €13bn Question: Is The Fiscal State Aid Era Over?

Number of pages: 9 Posted: 01 May 2024
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 74 (613,364)

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State aid, tax law, tax rulings, EU law, Commission, multinationals, Corporation Tax

18.

Administrative Inconsistency in the Courts

Judicial Review (Forthcoming)
Number of pages: 5 Posted: 17 Oct 2018
Stephen Daly and Joe Tomlinson
King's College London - The Dickson Poon School of Law and University of York
Downloads 70 (632,048)

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19.

Tinkler v Revenue and Customs: A Complicated Mistake?

[2021] 5 British Tax Review 558, King's College London Law School Research Paper
Number of pages: 9 Posted: 12 Jan 2022
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 68 (641,812)

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Taxation, Tax Administration, Estoppel by Convention

20.

Oversight of HMRC Soft Law: Lessons from the Ombudsman

(2016) 38(3) Journal of Social Welfare and Family Law 343-360
Number of pages: 34 Posted: 27 Jul 2017
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 67 (646,760)

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Ombudsman; tax law; public law; soft law

21.

The Power to Get It Wrong

(2021) 137(2) Law Quarterly Review 280
Number of pages: 38 Posted: 13 Apr 2020 Last Revised: 04 May 2023
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 64 (661,872)

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State Aid; Tax Law; Public Law

22.

Global Britain: Influencing Tax policy

(2023) King's Law Journal
Number of pages: 19 Posted: 03 May 2023
Stephen Daly and Martin Hearson
King's College London - The Dickson Poon School of Law and London School of Economics & Political Science (LSE) - Department of International Relations
Downloads 58 (693,706)

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Tax Law, Political Economy, Tax Treaties, Tax Negotiations, International Relations

23.

Commission v Luxembourg and Engie – (another?) mortal wound in the Commission’s campaign

[2024] 1 British Tax Review 91-103
Number of pages: 14 Posted: 23 Apr 2024
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 55 (710,610)

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State aid, tax law, tax rulings, EU law, Commission, multinationals, Corporation Tax

24.

Fiat v. Commission: a Misconception at the Heart of the Tax Ruling Cases

(2023) Modern Law Review
Number of pages: 13 Posted: 03 May 2023
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 40 (809,479)

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Tax Law, EU Law, State aid law, subsidies

25.

A positive concession? Murphy v HMRC [2023] EWCA Civ 497

[2023] 4 British Tax Review 515-525, King's College London Law School Research Paper Forthcoming
Number of pages: 11 Posted: 13 Feb 2024
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 18 (1,010,720)

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Tax Law, Guidance, Soft Law, Concessions, Administrative Law

26.

The OMC, Intelligent Accountability and Monitoring National Tax Authorities

Modern Law Review (2022): https://onlinelibrary.wiley.com/doi/10.1111/1468-2230.12730.
Number of pages: 25 Posted: 06 Apr 2022 Last Revised: 03 May 2023
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 13 (1,065,560)
Citation 1

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Constitutional & administrative law (public law), EU (Institutions), Tax

27.

Good guidance: Guidelines for Compliance and LITRG report

[2023] 4 British Tax Review 377-389
Number of pages: 13 Posted: 13 Feb 2024 Last Revised: 13 Mar 2024
Stephen Daly
King's College London - The Dickson Poon School of Law
Downloads 10 (1,098,749)

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Tax Law, Public Guidance, Soft Law

28.

Tax Systems - Adaptability and Resilience during a Global Pandemic

(2023) Accounting and Business Research
Posted: 03 May 2023
Stephen Daly
King's College London - The Dickson Poon School of Law

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Taxation; tax policy; soft law; tax state; digitalisation; fraud.

29.

The UK's implementation of ATAD

(2021) 49(6) Intertax
Posted: 03 Jun 2021
Stephen Daly
King's College London - The Dickson Poon School of Law

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Taxation, EU Law, UK Law, Tax Avoidance

30.

The Constitutional Implications of an EU Arm’s Length Principle

(2020) 60(2/3) European Taxation
Posted: 06 Mar 2020 Last Revised: 10 Mar 2020
Stephen Daly
King's College London - The Dickson Poon School of Law

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Tax, EU law

31.

The Relationship between Tax Authorities, Large Multinationals and the Public

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The Relationship between Tax Authorities, Large Multinationals and the Public

(2017) 71(5) Bulletin for International Taxation 243
Posted: 16 May 2017 Last Revised: 20 Apr 2020
Stephen Daly
King's College London - The Dickson Poon School of Law

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Tax, Multinationals, Revenue Authorities, Sweetheart Deals

The Relationship between Tax Authorities, Large Multinationals and the Public

Bulletin for International Taxation. - Amsterdam. - Vol. 71 (2017), no. 5 ; p. 243-249; DOI: https://doi.org/10.59403/2565jse
Posted: 11 Apr 2024
Stephen Daly
King's College London - The Dickson Poon School of Law

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tax authorities, MNE, APA