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                                                           October 23, 2024

Carl Anderson II
Senior Vice President and Chief Financial Officer
Axalta Coating Systems Ltd.
1050 Constitution Avenue
Philadelphia, Pennsylvania 19112

       Re: Axalta Coating Systems Ltd.
           Form 10-K for the Year Ended December 31, 2023
           Form 8-K filed August 1, 2024
           File No. 001-36733
Dear Carl Anderson II:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 8-K Filed August 1, 2024
Exhibit 99.1
Second Quarter 2024 Highlights, page 1

1.     Please expand the third bullet to present net income margin with equal
or greater
       prominence to Adjusted EBITDA margin. Ensure you discuss net income
margin
       within your financial results discussion. Refer to Question 102.10(a) of
the Non-
       GAAP Financial Measures Compliance and Disclosure Interpretations.
Reconciliations, page 8

2.     Your determination of multiple non-GAAP measures excludes step-up
depreciation
       and amortization which you note represents the incremental step-up
depreciation and
       amortization expense associated with the acquisition of DuPont
Performance
       Coatings. As a result, these non-GAAP measures only reflect part, but
not all, of an
       accounting concept. Please explain to us why it is appropriate to
exclude only the
       step-up depreciation and amortization from your non-GAAP measures and
how you
       considered 100.04 of the Non-GAAP Financial Measures Compliance and
Disclosure
 October 23, 2024
Page 2

       Interpretations.
3.     Please revise the title of your free cash flow measure to adjusted free
cash flow or a
       similar description as your calculation differs from the typical
calculation of cash
       flows from operating activities less capital expenditures. Refer to
Question 102.07 of
       the Non- GAAP Financial Measures Compliance and Disclosure
Interpretations.
       Please also tell us and disclose your basis for adjusting for interest
proceeds on swaps
       designated as net investment hedges in your determination of this
measure.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at
202-551-3691 if you
have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Industrial Applications and
                                                             Services
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