Camilla Sindahl Dahm

Student thesis: Master executive thesis


This thesis treats the area of hiring out labour based on the amended Act No 921 of 18 September 2012. The internal Danish legislation was amended in the area of workforce hired as part of reducing social dumping and as an alignment with international practice in the field of hiring out labour. The concept of hiring out labour was first incorporated into the OECD Model Convention in 1992 and remained largely unchanged until 2010 when the OECD’s interpretation of the concept of employer was radically revised. Due to difficulties of interpretation, SKAT (the Danish Tax Authorities) issued binding instructions in SKM2014.478.SKAT containing specific changes in practice concerning the interpretation of the concept of hiring out labour going forward which were to ensure an even higher level of harmonisation of Danish and international law and to reduce interpretation difficulties. The thesis analysis the regulatory framework after the amendment and the influence of the binding instructions from SKAT and evaluates as to whether these binding intructions are alignment with the Law. Based on the analyses of the Tax Authorities’ practice before and after the the binding instructions as well as the legislative work on which basis the law was adopted in 2012 the conclusion is that the binding instructions is getting the practice on the right track.

EducationsMaster i Skat, (Executive Master Programme) Final Thesis
Publication date2015
Number of pages62