BOLIVIA Law and Practice Contributed by: Ramiro Guevara, Jorge Inchauste and Rosario Echeverría, Dentons Guevara & Gutiérrez S.C.
Agreements. Currently, only one of these com - panies (Uranium One Group) has entered into a joint venture agreement with YLB for the devel - opment of a direct lithium extraction plant in the Salar de Uyuni. In 2024, YLB launched the Second Internation - al Public Tender to execute a project of Direct Lithium Extraction in the Bolivian salt flats. As a result of this tender, YLB is currently negotiat - ing agreements to develop lithium projects with CATL BRUNP & CMOC (China), Protecno S.R.L. (Italy), Eramet S.A. (France) and Eau Lithium PTY Ltd. (Australia). 4. Taxation of Mining and Exploration 4.1 Mining and Exploration Duties, Royalties and Taxes There are three sources of income for the Boliv - ian State from mining activities: • taxes; • mining royalty; and • mining tax right ( Patente Minera ). General Taxes The following taxes are applicable on mining operations: • Value Added Tax (IVA) equivalent to 13% of the sale or purchase value is recoverable through fiscal credit gained with the purchase of goods or services related to the operations of the company; • Transaction Tax (IT) equivalent to 3% of every transaction; • Company Income Tax (IUE) equivalent to 25% of the additional utilities generated by min - ing companies due to favourable conditions
related to the price of minerals and metals; and • Company Income Tax – Foreign Beneficiaries (IUE-BE) equivalent to 12.5% of the amount of money sent to other countries. When goods are exported, the GAC (Consoli - dated Customs Tax) must also be paid. The GAC is composed of the IVA, IT and an additional per - centage depending on the good that is import - ed. RITEX is a system for temporary importing of goods where the GAC payment is not required. Mining Royalty This payment does not fall into the specific cate - gory of tax, but it implies a burden on the mining producer and is assumed as part of the govern - ment’s take from mining activities. The mining royalty is based on the gross sale value of miner - als and varies between 3% and 7%, depending on the mineral and international market prices. Mining Tax Right A special mining tax is paid annually by min - ing titleholders to maintain their mining rights, at approximately USD6 per hectare. 4.2 Tax Incentives for Mining Investors and Projects To boost the smelting and refinery of metals, Article 224 of the Mining and Metallurgy Law provides a 40% discount off the mining royalty if the product is traded locally or to international markets as a metal bar. The Bolivian government has been discussing granting incentives to local and foreign compa - nies engaged in mining exploration.
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