Roné la Grange is a partner in the Corporate Department and a member of the Tax Practice.

Roné has over 20 years of corporate tax experience with significant involvement in financial services tax matters in key sectors such as banking, insurance, and private equity.  Her expertise also extends to exchange-traded funds, collective investment schemes, hedge funds, property funds and treasury operations.

Roné has consulted on a wide range of corporate tax matters, including but not limited to the implementation and collapse of black economic empowerment transactions, group restructures, management buy-outs, debt restructuring, private equity fund structures, employee equity incentives, finance and investment structures.  She has experience in tax due diligences, obtaining tax rulings, objection and appeals, settlement negotiations and general tax compliance.

Roné has BLC (cum laude) and LLB (cum laude) degrees from the University of Pretoria, an LLM in Tax from the University of the Witwatersrand, a Diploma in Company Law from the University of Johannesburg and a Diploma in Financial Markets.

Relevant Experience

Roné recently advised on the following types of transactions:

• Merger and acquisition transactions that included the delisting of Afrox from the JSE, the formation of a combined financial services investment structure for two listed groups, and other acquisition transactions that required post-acquisition integration restructuring.
• Having worked at an accounting firm for 17 years, Roné has experience in tax due diligence. At Bowmans, she has conducted a number of buy side due diligences and a vendor due diligence of a major South African group.
• The introduction of black economic empowerment, such as the black economic empowerment transaction undertaken by Bell Equipment Limited. Roné has been involved in a wide array of transaction structures, including notional vendor funding to suite specific needs, and broad-based incentivisation for staff on a continuous basis.
• Roné has of late been involved in several debt restructuring transactions The restructuring of external debt and the shareholder funding of companies in financial distress, taking into account cross border aspects. The restructure of foreign group companies and assets for sale to raise cash to settle bank debt. The recapitalisation and restructure of the debt and equity funding of a hospitality group following the raising of new debt.
• Several intra-group restructures to simplify and/or wind down business operations.
• The set up and refinancing of a project company that will engage in generating renewable energy.

Signature Matters

• AB InBev and SA Breweries’ B-BBEE Scheme

• South Africa: Limitation on the use of contributed tax capital
• South Africa: Recent tax court case deals with the deductibility of finance charges in terms of section 24J of the Income Tax Act
• South Africa: Beware – Your investment in a South African company could be taxed on repurchase
• South African National Budget Speech, 2021 – Key business tax issues
• 2020: An interesting year for tax in South Africa?
• Amending preference share terms without triggering tax
• South Africa – Supplementary Budget contains no specific tax reforms
• An increase in the Capital Gains Tax rate: would it make economic sense?
• Anti-dividend stripping provisions