This master thesis is designed to contribute to the interpretation of the scope of excise duties imposed on extraction of raw materials. With a particular focus on the tax- and registration obligations shown in article 1, subsection 1, and article 4, subsection 1 respectively, the thesis seeks to investigate whether it is compliant with applicable law to impose tax- and registrations obligations on a subcontractor in the context of the two binding tax rulings SKM2021.214.SR & SKM2021.215.SR. It is a well-known phenomenon that excise duties must be paid for specific goods, which the government attempts to regulate the citizens’ behavior and usage of. However, it is not clear whether imposing tax- and registration obligations on a subcontractor remains within the scope of the law (The Danish Tax Act on Waste and Raw Materials). Thus, this master thesis seeks to answer whether the binding tax rulings SKM2021.214.SR & SKM2021.215.SR constitutes an expression of applicable law, and if proven, the thesis seeks interpret the impact on the scope of the law, and the legal position that follows as a result. The legislation revolving extraction of raw materials has undergone multiple changes over time. The most extensive change was the transition from a fee legislation to a tax legislation. Despite the changes, it remains unclear what a commercial extraction implies, and there is no clear description of what the term contains. This exact term is essential for imposing tax- and registration obligations according to the law. This unclear definition of the term is problematic, because the law is subject to article 43 of the Danish Constitution, which includes strict legal requirements for tax laws, hence the interpretation of commercial extraction must remain consistent in accordance with legal authority. If authorities do not interpret tax issues in accordance with article 43 of the Danish Constitution, it will not be possible to legally impose any tax, including excise duties on goods. It is not possible to adequately deduce what commercial extraction implies merely from any version of the law. Therefore, it is necessary to interpret the intention of the term from earlier legislation. The legal dogmatic method will in this master thesis be used to analyze and interpret the term commercial extraction in order to deduce the applicable law. With the analysis it has been deduced that the term commercial extraction includes three elements. Firstly, to perform a commercial extraction, you must physically extract the raw materials from nature. Secondly, you must perform the physical extraction with the intention of selling the raw materials that are extracted. Lastly, you must own the extraction permit that allows for extraction of specific products in a designated area. All three elements must be present before those combined constitutes a commercial extraction. It is concluded that the binding tax ruling SKM2021.214.SR is legally compliant with case law. Thus, it constitutes an expression of applicable law. However, the binding tax ruling SKM2021.215.SR is not an expression of applicable law but constitutes an expression of new practice from the Danish tax authorities. The conclusion is based on our assessment of the applicable law, where the tax authorities in the binding tax ruling SKM2021.214.SR deduces the same result. In the binding tax ruling SKM2021.215.SR, the final decision the tax authorities make is not compliant with our assessment of the applicable law. Additionally, it is our assessment that a loophole exists within the law since it is not possible with our understanding of the term commercial extraction to impose tax- and registration obligations on a subcontractor as in the context of the binding tax rulings. However, it is also not possible to impose those obligations on a superior in the same context. For this reason, it is possible to avoid paying excise duties on raw materials by arranging a superior-subordinate relationship for the extraction. This contradicts the intention of the law. Thus, it is necessary to accurately define the term commercial extraction in future legislation to ensure that no unintended tax-planning takes place according to the intent of the law.