Not quite. Disguised employment is a pretty specific and (usually) clear-cut issue with well defined criteria. The problems start when a jurisdiction broadens the definition to include whatever they want because they want to capture more tax revenue.
IANAL, but I've been freelancing for years and had a similar thing come up. In the end I was found compliant with the law, ie: not in disguised employment.
IANAL, but I've been freelancing for years and had a similar thing come up. In the end I was found compliant with the law, ie: not in disguised employment.