Conclusions and recommendations
The situation prior to the 2005 Act
1. Gambling
is now widely accepted in the UK as a legitimate entertainment
activity. While we recognise the need to be aware of the harm
caused by problem gambling, it seems to us that the rather reluctantly
permissive tone of gambling legislation over the last 50 years
is now an anomaly. Our general approach in this report has therefore
been to support liberalisation of rules and delegation of decisions
to those most knowledgeable about their likely impacts, local
authorities, while keeping national controls to the minimum commensurate
with protection of the vulnerable, in particular children. (Paragraph
5)
Problem gambling
2. In
addition to the industry's voluntary annual contribution of £5
million for Research, Education and Treatment programmes, the
Government previously provided funding for the British Gambling
Prevalence Surveys. The Government has now withdrawn funding for
future British Gambling Prevalence surveys without giving any
indication that it has considered other options, either for obtaining
funding for similar studies elsewhere or for commissioning other
forms of research. We recommend that the Government works with
the Gambling Commission to provide a clear indication of how it
intends to ensure that sufficient high-quality research on problem
gambling is available to policy-makers. It is particularly important
that research is seen to be independent and comparable over time
to show whether or not there is a change in the levels of problem
gambling. (Paragraph 32)
Under-age gambling
3. We
note the wide variation between sectors in the ease with which
'under-age purchasers' have been able to evade the safeguards
designed to protect them from gambling. In particular, we are
very concerned about the continuing comparatively high failure
rate of betting shops (against other kinds of gambling premises),
which—thanks to the 2005 Act—are now able to host
casino-style roulette machines. We recommend that the Gambling
Commission continue to monitor the ability of children to access
gambling premises through regular test-purchasing schemes rather
than handing the responsibility to monitor and enforce age-restrictions
to the gambling industry. The Gambling Commission, working with
local authorities, should also take swift enforcement action where
an operator fails to introduce sufficient access and age-verification
controls. (Paragraph 38)
4. There has been
insufficient data collected to establish whether or not the 2005
Act has been successful in its aim of protecting children from
gambling. This highlights a particular need for more research
in this area. (Paragraph 39)
Gaming machines
5. We
were told by the Gambling Commission and by DCMS that gambling
policy must be evidence-based. It is apparent, however, that the
allocation of gaming machines under the 2005 Act is complex and
was not made on the basis of solid evidence about the risk of
problem gambling. (Paragraph 48)
6. Casinos are the
most highly-regulated sector and they are therefore the most appropriate
venue for hard, high-stake forms of gaming. This is not reflected
fully in the current allocation of machines. We believe that it
is illogical to restrict the games available in highly regulated
land-based casinos when B2s, with high stakes and prizes, can
be accessed in betting shops. The Government should address the
current imbalance by permitting casinos to operate up to twenty
B2-type machines with a maximum stake of £100. (Paragraph
53)
7. We recommend that
research be commissioned by the Gambling Commission to assess
the potential of types of gambling to contribute to problem gambling
levels, in particular whether there is a link between features
including speed of play, stake and prize levels, accessibility
and numbers of gaming machines, and problem gambling. (Paragraph
57)
8. The 2005 Act has
had the unintended consequence of encouraging the clustering of
betting shops in some high streets by removing the demand test
and limiting the number of B2 machines permitted in each premises.
The clustering of betting shops is a local problem which calls
for a local solution. We therefore recommend that local authorities
be given the power to allow betting shops to have more than the
current limit of four B2 machines per premises if they believe
that it will help to deal with the issue of clustering. The limit
of four B2 machines under current legislation should be maintained
as a minimum limit to create certainty for operators. However,
if problems arise with individual betting shop chains or premises
in connection with B2 machine use, local authorities should have—as
a safeguard—the right to require the removal of any machines
over the minimum allowance. (Paragraph 66)
9. We support the
original vision behind the 2001 Gambling Review Report in which
bingo halls were to be maintained as social, soft gambling environments.
In the case of Adult Gaming Centres we believe that they provide
a controlled adult environment and have robust access controls,
as demonstrated by their low failure rate in the Gambling Commission's
test-purchasing scheme. We therefore recommend that Adult Gaming
Centres are permitted B2 machines on the same basis as betting
shops. (Paragraph 69)
10. We recognise the
potential pitfalls of amending the Act to meet individual hard
cases and also note that it would be unlikely that the Government
would be able to find room in its legislative programme for such
amendments in the near future. However, it is clear that commercial
snooker clubs have suffered disproportionately from the removal
of B3 machines and are now struggling to remain profitable. We
therefore recommend that commercial snooker clubs be permitted
to offer B3 machines. (Paragraph 71)
11. We consider that
the decision to raise the stake limit on B3 machines was made
on the basis of little or no evidence. We welcome the Government's
position that further changes to machine stakes and prizes should
be evidence-based. (Paragraph 73)
12. It is important
that the likely effectiveness of any measures for tackling problem
gambling is assessed before such measures are put in place. We
recommend that the Department for Culture, Media and Sport seek
to learn from the experiences of other jurisdictions, such as
Australia, which have implemented measures to combat problem gambling
including educational programmes and machine displays showing
time spent on them. (Paragraph 74)
Tackling problem gambling
13. Despite
arguments that the 2005 Act changed little in reference to problem
gambling, we regard it as an important step forward that, for
the first time, the Act gave the Government the power—and
the gambling industry the responsibility—to tackle problem
gambling. (Paragraph 75)
14. We have seen that
information about problem gambling and sources of help has been
made available inside the gambling venues which we have visited.
An information campaign, aimed at the relatives of problem gamblers,
could lead to more people seeking help because relatives of problem
gamblers may not enter gambling venues and see the information
provided there. We recommend that the Department for Culture,
Media and Sport develop a public information campaign outside
of gambling premises to highlight sources of help for problem
gamblers and their relatives. The Government should also make
an assessment of the ability of existing support and advice centres
to deal with any significant resulting rise in demand. If a significant
increase is expected then the industry should fund, out of the
existing voluntary levy, increased provision of advice and support
by these existing centres. (Paragraph 77)
15. We recognise the
significant practical challenges that introducing a national "universal"
self-exclusion system would involve, including confidentiality
and legal issues. However, the Government should support the development
of a system which would allow a customer to self-exclude from
all forms of gambling regulated by the Gambling Commission. (Paragraph
81)
16. The voluntary
levy for research, education and treatment has thus far been successful
at raising the target of £5 million per annum. An important
lever for obtaining funds from the gambling industry is the potential
for reputational damage if insufficient monies were raised or
if a compulsory levy were deemed necessary. While it is important
that the option of enforcing a compulsory research, education
and treatment levy be maintained, we recommend that the current
voluntary levy is continued. However, should one or more sectors
of the gambling industry fall short in their duty to fund research,
education and treatment programmes, the Government should implement
a compulsory levy on those sectors. (Paragraph 84)
17. We recommend that,
in designing successor arrangements to the tripartite agreement
for the funding of research, education and treatment, the Department
for Culture, Media and Sport and the Gambling Commission focus
on minimising overlap between the responsibilities and activities
of the bodies involved as well as ensuring effective communication
between them. While the Responsible Gambling Strategy Board continues
to advise the Gambling Commission, and through it the Government,
we believe that the Department for Culture, Media and Sport should
also take a more pro-active role in identifying the research needed
for strategic policy development and ensuring that these needs
are reflected in the research being carried out. (Paragraph 91)
18. We support the
recommendations of the Responsible Gambling Strategy Board for
the principles which should apply to the successor arrangements
to the tripartite agreement as laid out in its 2011 Strategy document.
In addition, the advice from the Responsible Gambling Strategy
Board regarding the amount required for future research, education
and treatment, if accepted, must be clearly communicated to the
gambling industry. This advice should set out how the money donated
by the industry will be spent. We await with interest proposals
from the Gambling Commission for a replacement for the now defunct
system for funding and commissioning research, education and treatment
programmes. (Paragraph 92)
19. The Gambling Commission
should make an assessment of the available gambling education
programmes aimed at under 16 year olds—including that which
has been developed by GamCare—and make a recommendation
on their merits, based on projected cost and level of impact.
(Paragraph 96)
The industry, tax and regulation
20. We
recognise that the Bingo sector remains highly taxed in comparison
with other sectors despite its status as one of the softest forms
of gambling. In principle we believe that bingo should be taxed
in line with other forms of gambling at 15%. Moreover, we recommend
that the Treasury make an assessment, within the next financial
year, of the likelihood that a reduction in bingo duty, to 15%,
would result in increased investment in the bingo sector and a
rise in net tax take. (Paragraph 104)
21. We are not convinced
by arguments from the Treasury that measures to allow the offsetting
of Gross Profits Tax against VAT on capital investment for gambling
machines cannot currently be implemented. The Treasury should
carry out further work in this area and identify a means by which
such offsetting could be achieved. We also recommend that the
Treasury make judicious use of industry analysis of the likely
impacts of its proposed taxation measures. As it is in the public
interest to maximise the tax take from the gambling industry,
the Treasury should set tax at a level which allows investment
in the industry and does not stifle growth. We recommend that
the Treasury also take into account the likely impact on investment
by the gambling industry in future tax-rate calculations. We recommend
that any changes to machine gaming duty should be revenue neutral
as the Economic Secretary to the Treasury assured us that they
would be. If the rate of machine gaming duty raises more than
a revenue neutral figure, the Chancellor should reduce the new
rate to ensure that revenue neutrality is achieved. (Paragraph
109)
22. The failure of
the Department for Culture, Media and Sport to work with the Treasury
to set remote gambling taxation at a level at which online operators
could remain within the UK and regulated by the Gambling Commission
has led to almost every online gambling operator moving offshore
whilst most are still able to advertise and operate into the UK.
We therefore welcome the announcement, made in the 2012 Budget
Statement, that the online industry will be taxed on a point-of-consumption
rather than a point-of-supply basis. We also welcome the detailed
consultation with the industry since the Budget over the design
of the policy framework and look forward to the Government's response.
To give certainty to online operators, and their investment plans,
we urge the Government to adhere to its timetable for implementation
by December, 2014 and to make plans to deal with any challenges
to the proposed new system. However, the Treasury still needs
to work with industry stakeholders to establish the correct level
for online gambling taxation, taking into account the need to
encourage companies to accept UK regulation and taxation and to
discourage the formation of a grey market. (Paragraph 117)
Regulation and the impact of the Act
23. We
welcome the reinstatement of the Triennial Review system for gambling
machine stakes and prizes. These reviews should be designed to
maintain the value in real terms of stakes and prizes, as is the
case with other industries where prices are controlled by the
Government, rather than as a means of increasing industry profitability.
A Triennial Review system has the potential to lead to significant
calls from all sectors of the industry that they should have their
machine allowances and/or stakes and prizes increased on a regular
basis. It is important therefore that these reviews are carried
out on the basis of evidence, are as open and depoliticised as
possible. (Paragraph 124)
24. We have seen no
evidence to suggest that the existing White Listed jurisdictions
pose a greater threat of problem gambling than UK or EU-based
operators. However, the possible link between online gambling
and problem gambling must be addressed alongside any future regulatory
and licensing regime for online gambling. Online gaming has been
identified as having certain characteristics which may be associated
with problem gambling, including high speed of play, frequency
of play and ease of availability. We consider that a vital aspect
of gambling regulation is controlling the significant, and growing,
online sector with its unlimited stakes and prizes, and its potential
to cause problem gambling. The Commission's plans for licensing
online operators will rely heavily on other regulators which the
Commission has very limited means of monitoring. The Commission
should aim to improve its links with overseas regulators for the
purpose of spreading best-practice in terms of customer protection
and problem gambling prevention. (Paragraph 133)
Consumer protection in online gambling
25. We
welcome the assurances we have received from the Department of
Culture, Media and Sport that it will take into account the lessons
learned from the Full Tilt case, including the conclusions of
the Report by Peter Dean to the Alderney Gambling Control Commission
published in March 2012. We recommend that the Gambling Commission
should consider, as a part of efforts to communicate to online
gamblers the potential risks to their funds, introducing a kite-marking
system for gambling websites, indicating which sites are regulated
in the UK. This could protect consumers by encouraging them to
use UK-regulated sites and by incentivising suppliers to choose
to be regulated here. (Paragraph 138)
26. We recognise the
concerns of well-managed, existing operators about the potential
costs and burdens of legally separating players' funds. In the
light of the Full Tilt case, however, the Gambling Commission
should consult the industry as to what form of 'ring fencing'
or protection of player accounts, by all UK-regulated online gambling
operators, would be a proportionate response to the worries arising
from this unfortunate episode. (Paragraph 139)
Ensuring adequate regulation of online gambling
27. The
current regulatory framework for online gambling has failed to
create a level playing field between operators based in the UK
and those based overseas. This is because, whilst companies based
in the UK are subject to strict regulation and high taxation,
those based overseas can be lightly or unregulated whilst paying
little or no tax. This situation could allow unregulated—'grey'—markets
to emerge, able to attract UK customers because they can offer
better odds as the result of their lower cost bases. It is therefore
important that effective enforcement methods are put in place
to prevent unlicensed companies from operating into the UK and
that the Department for Culture, Media and Sport and other agencies
also work to encourage international co-operation and a common
approach. (Paragraph 151)
28. It is vital for
the Government to recognise that the success of any new regulatory
regime for online gambling will rest on the development and implementation
of effective enforcement mechanisms for regulation. The Government's
proposals for the regulation of remote gambling remain very unclear
particularly with regard to how the Gambling Commission intends
either to approve and monitor regulators in other jurisdictions
or to directly regulate and licence all the individual companies
which operate in the UK. It is not currently clear whether the
Gambling Commission intends to carry out licensing checks on all
companies that apply to operate in the UK. We recognise that it
would be unrealistic for the Commission to inspect directly individual
regulators across all other jurisdictions. We recommend that the
Commission should approve certain overseas regulators and continue
to monitor their performance where they meet its requirements.
The Commission should undertake test purchasing exercises to ensure
that these national regulators continue to carry out sufficient
licensing checks. Such an approach would have the merit of encouraging
international co-operation leading, in due course, to a more harmonised,
consistent and less bureaucratic regulatory system across the
27 member states. For the sake of confidence and market knowledge,
the Gambling Commission should also test whether regulators it
has not yet approved carry out sufficient licensing checks.
(Paragraph 154)
29. Even if the Gambling
Commission does not directly assess individual operators for their
suitability to hold a UK licence, it will therefore have to make
an assessment of which regulators it will allow to act as its
agents—regulating online gambling sites targeting the UK
on its behalf. The Department for Culture, Media and Sport should
make clear how the Gambling Commission will assess the effectiveness
of other national regulators and what the Commission will require
of its agents. Any additional regulatory activities will have
resource implications which the Gambling Commission will have
to address within its existing budget. (Paragraph 155)
30. Given that most
UK operators have located their online operations offshore, this
inquiry has heard concerns regarding the expertise of the Gambling
Commission to monitor effectively a much larger number of online
licence holders under the proposed changes to the regulatory regime.
The Commission will, therefore, need to bolster its capability
to do so, from within existing resources, as supplemented by licence
income from the online operators it approves. (Paragraph 156)
New Large and Small Casinos
31. We
believe that the stated aim of the Government—to test the
impact of the new casinos—would be almost impossible to
implement in a timely and cost effective manner due to the impracticality
of identifying whether any increase in problem gambling was caused
by the new casinos as opposed to the presence of any other forms
of gambling including online. The Government should reconsider
its plans to test the impact of the new casinos. Given that casinos
have some of the most comprehensive measures for tackling problem
gambling and in the light of some of our other recommendations
we believe that casino operators will already be doing enough
to enable the industry to grow safely. (Paragraph 163)
32. The delays in
the licensing process for new Small and Large Casinos are significant
and the result of an overly complex and bureaucratic process imposed
on local authorities. Insufficient guidance was provided by central
Government to the licensing authorities which has led to increased
consultation and administrative costs. The Government should review
the licensing process for Small and Large Casinos with a view
to developing a new simplified and less expensive licensing process.
(Paragraph 164)
33. Both the 1968
and 2005 Act provisions successfully prevented casinos from proliferating
or clustering. However, there is no evidence that allowing local
authorities to decide independently whether or not they wish to
have a casino would lead to a significant increase in the total
number of casinos. We believe that the decision as to whether
a casino would be of benefit to a local area should be made by
local authorities rather than central diktat. We recommend that
any local authority be able to make the decision as to whether
or not they want a casino. As a step towards this, we recommend
that existing 1968 Act Casino licences are made portable, allowing
operators to relocate to any local authority provided that they
have the consent of that local authority. The portability of these
licences would be constrained by the existing 'triple lock' contained
in the Gambling Act: the need to obtain local authority approval,
a premises licence and planning permission. (Paragraph 165)
34. The Act has created
a situation where the Small Casino model is not considered financially
viable. This is partly because a Small Casino must possess a larger
floor-area for table play than a Large Casino in order to maximise
its machine allowance. We note that not one Small Casino has been
developed. It was not Parliament's intention in 2005 to make Small
Casinos completely unviable. Given the fact that all casinos are
highly regulated and access is limited regardless of the size,
we see no rationale for the different gaming machine allowance.
As 5:1 is the ratio presently in the legislation, we recommend
that the Government introduce a single ratio of five machines
to one table for both Small and Large Casinos. Local authorities
should have the power to increase the number of machines permitted
per table if they wish to do so and an operator requests it.
(Paragraph 169)
1968 Act Casinos
35. There
is now a two-track system for casinos, with existing 1968 Act
Casinos unable to modernise and take advantage of the allowances
granted to new Small and Large Casinos. However, as the development
of these new casinos has been so slow following the Act—with
only one Large Casino having opened to date and two more having
been permitted—there is currently no way of assessing what
impact allowing 1968 Act Casinos the same freedoms would have.
In principle, we see no logical reason for maintaining different
regulatory regimes and believe that 1968 Act Casinos should be
given the same freedoms as new ones. (Paragraph 172)
Regional Casinos
36. The
current wariness of casino operators about re-entering the debate
on Regional Casinos has partly resulted from the confusion created
after the passage of the 2005 Act and the misjudged process for
selecting a location. Another factor making the development of
Regional Casinos in the UK relatively unattractive is the UK's
comparatively high rate of casino duty. We recognise that changing
this would be extremely contentious and is unlikely to be considered
in the near future. We conclude therefore, that the opportunity
to establish one or more Regional Casinos in the UK has passed
and, without a change in the political and economic climate, is
unlikely to reoccur. (Paragraph 183)
The Gambling Commission
37. The
Gambling Commission needs to provide greater clarity about what
it means by moving away from a blanket stake and prize regime.
We are concerned that a move towards allowing individual venues
or operators to have stakes and prizes set at a different level
to the rest of the market—because the Gambling Commission
considers that they are well controlled—could destabilise
the regulatory pyramid. (Paragraph 197)
Gambling Commission fees
38. Disagreement
between the regulator and the industry it regulates over the appropriate
level for licensing fees is unsurprising to the extent that no
business welcomes costs imposed upon it. However it is important
that the industry has a clear understanding of why it has to pay
certain fees and what it is getting in return. It is clear from
some of the evidence we have received that this is not always
the case. We recommend that the Gambling Commission provide the
gambling industry with a clear and easily accessible summary of
where the fees it charges are spent as a part of its Annual Report.
This would improve the relationship between the Commission and
the industry, as well as highlighting areas where value for money
is not currently being achieved. This requirement should also
help to reduce well intentioned mission creep by the Commission
into areas such as sports integrity, which is—and should
continue to be—the responsibility of the sports' governing
bodies. (Paragraph 202)
39. We remain unconvinced
by arguments from the Gambling Commission that changing the licence
fee banding system would lead to too much complexity. On the contrary,
the current system is too simplistic and in some cases leads to
the ridiculous situation where operators face steep fee increases
when they open just one new premises. The Commission should introduce
a new licence fee structure which gives a much clearer reflection
of the amounts charged per shop. Small independent operators should
certainly be paying less than they are now. The Commission should
also be looking to charge large operators less than they currently
are. (Paragraph 203)
40. Particularly given
the absence of a significant UK-regulated online sector or any
Regional Casinos, the Gambling Commission remains an overly expensive,
bureaucratic regulator. We consider that the Commission has not
gone far enough, in particular, in its efforts to reduce its operating
costs. We recommend that an independent review of Gambling Commission
expenditure be carried out as soon as possible after a new system
for remote licensing is in place. We consider that it is important
for such a review to be carried out externally so that the industry
has confidence in its conclusions. The reviewing body should have
the power to recommend changes to the Commission with a view to
reducing its costs and the regulatory and fees burden imposed
on the industry taking into account the Commission's ability to
fulfil its licensing objectives. (Paragraph 204)
Role of the Gambling Commission
41. We
concur with the view taken by the 2008 Hampton Review Report that
allowing the economic progress of a regulated industry is an important
role of any regulator and that the Gambling Commission should
only intervene when necessary to protect the consumer. However,
the Gambling Commission should not have an explicit duty to encourage
economic progress in the gambling industry. Whilst we believe
that the Gambling Commission's primary objectives, and its ability
to maintain a good relationship with all gambling stakeholders,
are best served by it remaining as an impartial regulator, there
is no such barrier to the Department for Culture, Media and Sport
having a more supportive role towards the industry. Despite the
statement, displayed on the website for the Department for Culture,
Media and Sport, that it is a sponsor for the gambling industry,
it makes no mention of the gambling industry in its Departmental
Business Plan of 2011/15. We call on the Government clearly to
set out its position on whether the gambling industry constitutes
a legitimate mainstream leisure pursuit and whether it intends
to be a pro-active sponsor of, or simply to tolerate, the UK gambling
industry. (Paragraph 208)
42. Evidence from
the amusement and arcade sectors, in particular, suggests that
the Gambling Commission has not been able to develop strong relationships
and lines of communication with some smaller operators. (Paragraph
211)
43. During this inquiry
we have found the Gambling Commission's website, which should
be a significant tool for communication, frustrating. This should
not be the case with a modern regulator and we recommend that
the Commission move quickly to rectify any technical or design
issues which prevent its website from being an effective communication
tool. Specifically, the Gambling Commission should ensure that
the search engine built into its website is functional and that
links are maintained. (Paragraph 212)
44. The Gambling Commission
needs to continue to make improvements in the way it communicates
with the businesses it regulates, particularly when conveying
the reasons behind its regulatory activity. In particular, it
should ensure that the purpose of requests for data are made clear.
(Paragraph 214)
45. We welcome the
Gambling Commission's moves to improve communication channels
between it and local authorities through the creation of a liaison
unit. The Commission should provide clear, accessible guidance
to operators and local authorities, setting out its regulatory
responsibilities and those of the local authorities. This would
help to avoid regulatory and enforcement activity falling between
the two responsible bodies. (Paragraph 218)
Merger of Gambling and National Lottery Commissions
46. The
Government and both Commissions should clarify what effect the
planned merger of the Gambling Commission and the National Lottery
Commission will have on the objectives, regulatory policies and
practices of the resulting unified regulator, in particular the
newly merged regulator's approach to society and charitable lotteries
and the National Lottery. (Paragraph 222)
47. The move to Birmingham
came at a time of transition, with the development of the Commission
from the old Gaming Board of Great Britain and the implementation
of the new Act. It is therefore difficult to assess the true impact
of the relocation in terms of reduced costs. We would expect the
merger of the Gambling Commission and the National Lottery Commission
in Birmingham to be completed within the next year. This merger
should produce significant savings. The Gambling Commission should
continue to effect cost-saving measures as a part of its merger
with the National Lottery Commission wherever these would not
interfere with its statutory objectives. (Paragraph 225)
Lotteries
48. While
the Health Lottery appears to us to accord with neither the spirit
nor the intention of Parliament as set out in the National Lottery
Act 2006 and the Gambling Act 2005, we cannot comment on its legality
or make any other recommendation, in light of the recently announced
Judicial Review. (Paragraph 229)
49. The Government
should provide clarity one way or the other as to what constitutes
a national lottery and what constitutes a local lottery connected
to other local lotteries. If the Government decides to allow more
than one national lottery then it should ensure fair competition
by requiring any new national lottery provider to pay lottery
duty and meet the same legal requirements as the existing National
Lottery operator. (Paragraph 230)
50. The 2005 Act has
created a situation where small society lotteries are required
to hold ancillary licences for remote gambling, increasing their
operating costs through additional administrative burdens and
fees. We recommend the immediate and practical solution of making
ancillary remote licences free of charge for small society lotteries.
This would not, however, have any effect on the amount of bureaucracy
involved in small lotteries making licence applications and renewals.
We recommend that the Department for Culture, Media and Sport
work with local licensing authorities to review the registration
process for small society and charity lotteries with a view to
reducing their administrative burdens. (Paragraph 233)
51. We recommend that
the Government should establish whether there is evidence that
the National Lottery would be adversely affected by society lotteries
with the right to offer increased or unlimited prizes. If it cannot
be demonstrated that the current limits on small lotteries are
necessary to protect the National Lottery from competition, then
they should be reduced or removed. If the limits on small lotteries
are removed then they should be subject to lottery duty on the
same basis as the National Lottery. (Paragraph 235)
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