<DOCUMENT>
<TYPE>EX-8.1
<SEQUENCE>5
<FILENAME>dex81.txt
<DESCRIPTION>OPINION OF BAKER & MCKENZIE
<TEXT>
<PAGE>

                                                                     Exhibit 8.1

                                                          WILLEM C.B. VAN WETTUM
                                                                     020-5517414

QIAGEN N.V.
Spoorstraat 50
5911 KJ  VENLO
The Netherlands

June 24, 2002
68-083443-0/WCW/FFR

Re: Qiagen N.V. Secondary Public Offering by Certain Selling Shareholders

Dear Sirs,

We have acted as Netherlands tax counsel to QIAGEN N.V., a Netherlands
corporation (the "Company"), in connection with the secondary public offering by
certain selling shareholders of the Common Shares in the Company which is
described in the Registration Statement on Form F-3, as filed with the
Securities and Exchange Commission ("the Prospectus") and in certain documents
incorporated by reference into the Prospectus. All capitalized terms, unless
otherwise specified, have the meaning assigned to them in the Prospectus.

We express no opinion as to any laws other than the current Netherlands tax laws
and regulations. There can be no assurance that a change in the existing laws
and regulations would not occur in the future which may have the effect of
altering our opinion.

Based upon and subject to the foregoing we are of the opinion that the
statements in the Company's Annual Report on Form 20-F for the fiscal year ended
December 31, 2001 (a copy of which is attached), under the caption "Taxation --
Netherlands Tax Considerations", incorporated by reference into the Prospectus,
summarize the

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June 24, 2002

material tax consequences under Netherlands laws of an investment in the Common
Shares.

In this opinion, Netherlands legal and fiscal concepts are expressed and
described in English language terms and not in their original Netherlands
language terms. These concepts may not be identical to the concepts described by
the equivalent English language terms.

This opinion is furnished to you and may not be relied upon by, transmitted to
or filed with any person, firm or company or institution without our prior
written consent. We hereby consent to the filing of this opinion as an exhibit
to the Registration Statement. We also consent to the incorporation by reference
of this consent into any subsequent registration statement filed pursuant to
Rule 462(b) under the Securities Act of 1933 in connection with the offering to
which the Registration Statement relates. We also consent to the references to
Baker & McKenzie under the headings "Taxation -- Netherlands Tax Considerations"
and "Legal Matters" in the Registration Statement.

This opinion is strictly limited to the matters stated herein and is not to be
read as extending by implication to any matters not specifically referred to
herein.

Yours sincerely,

/s/ Baker & McKenzie
Baker & McKenzie
Willem C.B. van Wettum

</TEXT>
</DOCUMENT>
