Procedural Context and Core Submission

This document is the Claimant's Post-Hearing Reply in a PCA-administered arbitration against the Plurinational State of Bolivia. Submitted following the hearing on the merits and quantum, it serves to rebut arguments made in the Respondent's Post-Hearing Brief. The Claimant's central thesis is that its valuation of the expropriated assets is supported by the preponderance of the evidence adduced at the hearing, including what it characterizes as numerous concessions made by the Respondent's own expert and fact witnesses during cross-examination.

Valuation of Expropriated Assets

The submission dedicates significant analysis to the valuation of the Colquiri Mine. The Claimant contends that, contrary to Bolivia's position, the evidence demonstrates the mine was undergoing expansion pursuant to an approved "Triennial Plan" at the time of the taking, with budgeted capital expenditures in place. It further argues that the mine had a long history of replenishing its mineral reserves and would likely have continued to do so, refuting Bolivia's valuation which assumes no replenishment. The Claimant attacks the Respondent's expert's proposed discounts to the certified reserves and resources as being based on subjective "feelings" rather than objective evidence or standard industry practice.

The Reply also addresses the valuation of the Vinto Tin Smelter and the Tailings Plant. The Claimant defends its US$53 million valuation for Vinto, contrasting it with Bolivia's US$17 million figure, by pointing to the asset's historical profitability. It argues that Bolivia's assertion of a "zero value" for the Tailings Plant is contradicted by expert testimony confirming the project was technically feasible and that development work had commenced prior to the expropriation.

Discount Rates and Interest

A key area of dispute addressed is the appropriate discount rate for the DCF analysis. The Claimant defends its proposed rates (12.3% for Colquiri and 15.7% for Vinto) as being consistent with market benchmarks and prior arbitral awards involving Bolivia. It strongly critiques the Respondent's much higher proposed rates (22.1% and 28.5%), arguing they are based on a flawed and unorthodox methodology. Specifically, the Claimant objects to the Respondent's calculation of the country risk premium, which it argues lacks precedential support, and the application of an additional "illiquidity/size" premium, which it contends is inappropriate for the valuation of a controlling stake in an emerging market asset.

The Claimant reiterates its entitlement to compound interest at the rates published by Bolivia's Central Bank, arguing this reflects the "normal commercial rate" required by the applicable bilateral investment treaty. It cites the tribunals' reasoning in *Rurelec v. Bolivia* and *South American Silver v. Bolivia* as support for its interpretation and for rejecting Bolivia's proposal of a risk-free rate.

Tax Treatment and Final Relief

Finally, the Claimant argues for an award to be issued net of all applicable existing Bolivian taxes. It asserts that this is necessary to protect the finality and efficacy of the award and to ensure full reparation under international law, as any subsequent taxation by the Respondent would diminish the compensation to which it is entitled. The document concludes by referring the Tribunal to its request for relief as detailed in its Post-Hearing Brief.