A discussion paper outlining the options for the new scheme said the average effective rate of tax on gaming machines in the ACT was the lowest of all states and territories, and was considerably lower than those applying in Victoria, Queensland and South Australia.

In the ACT, tax is levied on monthly gross gaming machine revenue, which is the expenditure on gaming machines less prizes payable.

Tax rates are progressive and increase with gaming revenue.

Ten of Canberra's 45 clubs paid no gaming tax in 2016-17 because they had a gross gaming revenue of less than $300,000 per year.

On the other end of the spectrum, six clubs paid the top marginal tax rate of 23 per cent because they had annual revenues of $7.5 million or higher.

But Clubs ACT has released data to show most clubs would be better off under the NSW taxation regime.

Its chief executive Gwyn Rees said comparing the tax rates in the ACT was not as simple as saying it is 28 per cent in NSW and 23 per cent in the ACT.

"For example, both jurisdictions have a tax-free threshold. In NSW this is $1,000,000, but in the ACT just $300,000," Mr Rees said.

"Taking this into account, clubs in the ACT are actually taxed at over $4 million more a year than they would pay in NSW.

“Only four clubs are better off under the ACT system - and one of these still couldn’t make a go of it and has recently closed."

Mr Rees also said the discussion paper skirts over the other costs facing clubs, like liquor licence fees, commercial rates, and maintaining recreational facilities.

He called on the directorate to recall or correct the paper.

A spokeswoman for the Justice and Community Safety Directorate said they would not be doing that.

"The Justice and Community Safety Directorate included factual information relating to taxation rates in the options paper. The options paper is focused on considering how the community contributions scheme could be improved to deliver the greatest value to the community," she said.

"The effective tax rate indicates the level of tax revenue raised compared to the overall base, which in this case is gross gaming machine revenue. It is a way of comparing the 'aggregate' level of revenue raised between different a jurisdictions, based on actual data collected by each State Government.

"The effective tax rates does take into account the overall turnover of clubs or the tax free threshold. It is not intended to apply to individual clubs, and does not take account for the circumstances of different clubs."

She also said the directorate expected to receive input about the cost of operating clubs during the consultation process.

Clubs and members of the community have until August 12 to comment on the proposed schemes.