Mogola Makola is a partner in in our Johannesburg office who specialises in domestic and international tax, with a specific interest in the financial services and private equity sectors. Her experience covers both South African and International tax. She has advised on major M&A transactions and has experience in advising on the tax structuring of offshore investments, derivative trades, investments in private equity funds, securities lending transactions, private equity fund formations and tax structuring. In addition to advising clients, Mogola also assists clients in tax disputes.

Mogola serves on Bowmans’ Remuneration Committee and of the Bowmans Partnership Board.

Mogola re-joined Bowmans in January 2019 after leaving in 2017 to make a contribution to the broader community in the public sector where she spent 15 months at the South African Revenue Service (SARS) in the senior position of Chief Officer: Enforcement.  In her role as the Chief of Enforcement Mogola was also part of the executive management team of SARS. This enabled Mogola to develop strong working relationships with other regulators, both domestically and internationally. These relationships have stood in her and the team in good stead in servicing clients.

During her employ at SARS, Mogola was responsible for the management of the Investigative Audit, Criminal Investigations, Anti-Corruption, Compliance Audit, Debt Management and Illicit Economy Units.  This experience gave her valuable insights into the workings and processes at the regulator which complements her skill set, and her ability to effectively ad well and has enabled her to develop and good working relationships with SARS and other regulators.

She has BA and LLB degrees from Rhodes University and an LLM from the University of the Witwatersrand.

Relevant Experience

• Advising on the acquisition by Ardagh Group of all the shares in Consol Holdings Proprietary Limited, for USD 1 billion;
• Advising on the sale by Lanxess of its 74% stake in a Chrome Mine in Rustenburg to Clover Alloys (SA) Proprietary Limited;
• Advising on the sale by Lanxess of its chrome chemical business to Brother Enterprises, a Chinese leather chemical producer;
• Advising Rand Merchant Holdings in respect of the unbundling of its shareholding in FirstRand Bank;
• An international telecommunications company in respect of its Broad Based Black Economic Empowerment Transaction;
• Assisting clients in engaging the National Treasury Department in relation to proposed amendments to the tax legislation affecting them;
• Advising the South African government in respect of the restructuring of a State Owned Company;
• Assisting clients in disputes with SARS, including transfer pricing disputes;
• Advising on certain aspects of the unwinding/ implementation of SAB’s 8.45% 2010 B-BBEE transaction (“Zenzele 1.0”);
• Advising an international bank in respect of a convertible bond transaction;
• Advising a South African publishing company in respect of the implementation of a BEE employee share incentive scheme.

• Chambers and Partners: The Corporate Tax 2022 Guide: South African Chapter
• South African National Budget Speech, 2021 – Key business tax issues
• South African provident funds annuitisation: Feel it – it is here (and no, it is not the world cup)!
• 2020: An interesting year for tax in South Africa?
• South Africa: Latest tax developments regarding employer-provided scholarships and bursaries
• COVID-19: Additional tax relief, South Africa
• COVID-19: Disaster management tax relief
• Providing tax certainty in an uncertain oil and gas world
• Certainty in the taxing of Collective Investment Schemes
• Global Legal Insights – Corporate Tax
• Getting the Deal Through – Private Equity 2013
• Getting The Deal Through – Private Equity 2012
• What is the structure of the retail funds market? What have been the main trends over the last year?
• Private Equity: Significant Regulatory Developments