Having just rewatched it for the first time in ten years, I think you have to be really quite averse to dark humour in general if you can't appreciate this. I mean, even at the most shocking moments they manage to find a way to make it funny: while he's smothering the kid, he's talking about how infanticide is generally more trouble than it's worth and during the rape scene you have the sound guy awkwardly trying to control the boom mic as he's drunkenly trying to get his end away. Both are laugh-out-loud funny moments with the right set of eyes, even if they involve disturbing themes. That's what dark comedy is.
More than anything it's a character piece though, and no film better sums up the phrase "the banality of evil". Instead of romanticising or glorifying a serial killer like most films do, it just portrays him as this rather dull, rambling narcissist with zero self-awareness. He's like David Brent, basically, and the juxtaposition of that with him indiscriminately murdering people is rife with comedy. I honestly don't get how anyone would fail to see that, but then again "dark comedy" is a term that's widely overused without people ever giving much thought to what it actually means.
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