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Mailstop 3233
                                                                May 14, 2018


     Via E-Mail
     Matias I. Gaivironsky
     Chief Financial Officer
     IRSA Inversiones y Representaciones Sociedad An nima
     Moreno 877 24th Floor
     Buenos Aires, Argentina

            Re:     IRSA Inversiones y Representaciones Sociedad An nima
                    Form 20-F for the fiscal year ended June 30, 2017
                    Filed October 31, 2017
                    File No. 001-13542

     Dear Mr. Gaivironsky:

            We have limited our review of your filing to the financial
statements and related
     disclosures and have the following comments. In some of our comments, we
may ask you to
     provide us with information so we may better understand your disclosure.

            Please respond to these comments 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 our
     comments apply to your facts and circumstances, please tell us why in your
response.

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

     Form 20-F for the fiscal year ended June 30, 2017

     Item 5. Operating and Financial Review and Prospects

     Critical Accounting Policies and Estimates, page 141

     Effects of foreign currency fluctuations, page 145

     1.     We note your disclosure that depreciation of the Peso increases the
value of your
            properties as measured in Pesos as typical real estate transactions
in Argentina are
            negotiated and prices are set in US Dollars. Please provide us more
detail about your fair
            value calculation for investment properties. In your response,
please explain in greater
            detail why the value of assets not denominated in U.S. dollars have
fair values dependent
            on the exchange rate between the U.S. dollar and your functional
and presentation
            currency.
 Matias I. Gaivironsky
IRSA Inversiones y Representaciones Sociedad An nima
May 14, 2018
Page 2

Consolidated Financial Statements

10. Investment Properties, page F-73

2.     Please tell us the factors that lead to your decision to change your
accounting policy with
       respect to the valuation of investment properties. In your response,
tell us the factors that
       lead you to initially select cost basis for valuing your investment
properties, and the
       changes in circumstances that lead you to revise your policy. Please
refer to paragraph 14
       of IAS 8 and paragraph 31 of IAS 40 in your response.

3.     Please explain to us how you determined certain investment properties
should be
       classified in level 2 of the fair value hierarchy. In your response,
tell us the lowest level
       of input that is significant to the measurement of these properties, and
explain to us how
       that input falls within level 2. Refer to paragraphs 81 to 85 of IFRS
13.

Form 6-K filed February 27, 2018

Summary as of December 31, 2017, page 2

4.     We note your inclusion of the non-IFRS performance measures EBITDA and
Adjusted
       EBITDA. In future filings, revise your disclosure to provide a
quantitative reconciliation
       of the differences between these measures and the most directly
comparable financial
       measures calculated in accordance with IFRS.

7. Investment Properties, page 11

5.     Tell us how you considered the need to disclose the business or economic
circumstances
       that lead to the change in value of your investment properties during
the period, including
       the material assumptions used in the valuation of your properties and
related sensitivity
       analyses. Reference is made to paragraph 91 of IFRS 13 and paragraph 15
of IAS 34.

        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.
 Matias I. Gaivironsky
IRSA Inversiones y Representaciones Sociedad An nima
May 14, 2018
Page 3


       You may contact Eric McPhee at (202) 551-3693 or the undersigned at
(202) 551-3438
with any questions.


                                                        Sincerely,

                                                        /s/ Robert F. Telewicz,
Jr.

                                                        Robert F. Telewicz, Jr.
                                                        Branch Chief
                                                        Office of Real Estate
and
                                                         Commodities
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