In its evidence, the GBGA raised concerns about the fundamental difficulties with UK government plans to impose the said duty and the anomalous and unfair results that are likely to arise.

It says the provisions in the Bill and the Gambling Tax Reform 2014 Information Notes show that drawing a distinction on a place of consumption basis is inherently difficult and the UK government's proposals are unworkable. Citing examples, it said that the conditions set out by the Bill for the circumstances in which duty will be chargeable are ‘framed exceptionally widely, are poorly defined and are inconsistent’.

The evidence also touches on the inadequate information gathering and enforcement powers of HMRC and the competitive advantage granted to operators that do not register for tax.

The association is urging the UK government to conduct a full impact assessment to determine the impact of the proposed regime on overall receipts.

Acknowledging that a solution is required that meets the UK government's objectives, is compliant with EU law and is in the interests of UK consumers, the GBGA is recommending a headline rate of below 10%; excluding from taxation items that do not constitute genuine receipts (such as free bets), marketing costs, integrity and compliance costs and software costs; allowing double taxation relief; and proper monitoring of the effects of the duty regime on the industry and consumer protection.

The proposals in relation to deductions are designed to ensure that licensed, tax-paying operators are still in a position to attract customers whilst complying with their licensing and tax obligations.

The memo from the GBGA is available here