Megan Ruigrok

Megan Ruigrok

Associate
Baker & McKenzie Amsterdam N.V.

Biography

Megan is a Dutch lawyer with more than seven years experience with tax dispute resolution, procedural tax law, international tax law, DAC6 (Mandatory Disclosure) and transactional work.

She represents clients during all stages of tax disputes, including (cross-border) audits, administrative appeals and litigation and she assists clients with tracking global tax controversies, MAP procedures and legal opinions. Her experience encompasses a broad range of issues, including disputes on: transfer pricing, business restructurings, corporate income tax, information obligations, exchange of information, effective place of management and tax residency/permanent establishments.

Megan represents clients from a wide variety of industry sectors before the tax courts in the Netherlands and advises clients in a wide variety of industry sectors on tax matters.
Megan spent a year on secondment in our Chicago office with our US Tax Controversy team and has experience with US and international Tax Controversies.

She also advises clients in a wide variety of industry sectors on tax matters and Mergers & Acquisitions, including but not limited to due diligence, SPA negotiations, W&I policy negotiations and specific Tax Insurance policy negotiations.

Practice Focus

Megan concentrates her practice on tax audits, prevention of tax disputes, procedural tax law, tax litigation on both international and domestic issues and M&A. She has extensive experience in discussions/negotiations the tax authorities, discussions/negotiations of transactional documents and tax litigation, including litigation before the Dutch Supreme Court.

Representative Legal Matters

  • Advised the shareholders of Heinenoord with the sale of 70% of the shares in Heinenoord Group 

  • Represented a Japanese multinational regarding a request from the Japanese authorities to the Dutch authorities to exchange information before the District Court and the Council of State. We successfully delayed the exchange of information.

  • Represented a German institutional investor in a dispute with the Dutch tax authorities in relation to real estate transfer tax before the District Court, the Court of Appeal and the Supreme Court. The client was awarded a refund of close to EUR 1 million.

  • Represented a Dutch taxpayer in a dispute with the Dutch tax authorities regarding the transfer pricing implications of a large business restructuring. The District Court confirmed the strong procedural rights for taxpayers with solid transfer pricing documentation. This was the first ever Dutch court case on transfer pricing and business restructuring. During the higher appeal procedure, a settlement was reached.

  • Representing a Dutch taxpayer, part of a multinational group in the commodity business, on the transfer pricing implications of a large business restructuring. The appeal before the District Court is pending.

  • Representing a company operating in the online business (and established outside of the Netherlands) in a discussion about its taxable presence in the Netherlands, i.e. whether its effective place of management is in the Netherlands or not and in a discussion about the information obligations of non-Dutch entities in the Netherlands. The appeal before the District Court is pending.

  • Representing several wealthy individuals in disputes with the Dutch tax authorities about their place of residence.

  • Representing pro bono client in a dispute with the DCFS in Chicago.

  • Acting for multiple clients in discussions about exchange of information requests.

  • Acting for multiple clients assisting them during audits of the Dutch tax authorities and during cross-border audits.

Professional Associations and Memberships

  • Dutch Association of Tax Advisers (NOB)

Admissions

  • Amsterdam Tax Law~Netherlands (2014)

Education

  • University of Amsterdam (Bachelor of Law) (2020)
  • Maastricht University (Master Tax Law (Indirect Tax and Direct Tax)) (2013)
  • Maastricht University (Bachelor Fiscal Economics) (2011)

Languages

  • Dutch
  • English

Previous Offices

  • Chicago

Megan is a frequent speaker at seminars and frequently publishes articles in renowned (tax) magazines.

Publications: 

Co-Author, "The Netherlands: European Member States Reach Consensus on Reporting Obligation for Digital Platform ("DAC7")," Baker McKenzie Tax Alert, December 2020

Co-Author, "De impact op de relatie tussen een bank en haar cliënt van DNB’s ‘Good Practices’ ten aanzien van fiscale integriteitsrisico’s" Maandblad voor Vermogensrecht, December 2019

Co-Author, "Big Brother is Watching You(r) M&A-transactions," M&A Magazine, October 2019

Co-Author, "De Nederlandsche Bank vraagt van banken fiscaal wensrecht te creëren," Financieel Dagblad (Dutch financial times), August 2019

Co-Author, "Netherlands: Legislative Proposal Implementing EU Rules on Disclosure of Cross-Border Tax Arrangements," Baker McKenzie Tax Alert, July 2019