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system incentivises some operators to not comply, putting compliant operators at a disadvantage and jeopardising the objectives of increased consumer protection and/or raising tax revenues.” The black (and grey) market question is one addressed by Williams. However, she was unable to provide concrete ?gures on the size of the current black market, stating: “By de?nition we don’t know [its size] but I would estimate it to be below 5% [of money] in the market.” Concerns remain, such as those raised by Paddy Power, that operators licensed in other EU-compliant jurisdictions could be reluctant to comply with an unfavourable regime, thus seeing the UK go the way of markets such as Italy, where there remains a dot. com element with what some dot.it operators see as a considerable competitive advantage, as opposed to Denmark, where an estimated 90% or more of the regulated egaming market has been captured. He adds: “In running the change in licensing in parallel with the change in taxation, we believe it is more likely than not that the government will not be able to put through the change in duty regime.” This view is contested by the GBGA through its own evidence, which describes the draft bill as “misconceived” and “unwarranted”, arguing: “It is inappropriate for the UK to be seeking such fundamental reforms to the licensing and taxation of online gambling just as the EU Commission is formulating policy at the European level.” Both Jenny Williams and Jonathan Stephens acknowledged examples of strong regulation elsewhere in Europe, paying particular attention to the Danish regime. Stephens says: “Their market is very similar to ours so we’re in regular contact with them. However, other countries are not very good comparators as either they have a more limited range of options or relatively high tax rates.” The consistency argument is one that Williams and Stephens have looked