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                                                            June 11, 2019

Leandro Iglesias
Chief Executive Officer
iQSTEL Inc.
300 Aragon Avenue, Suite 375
Coral Gables, FL 33134

       Re: iQSTEL Inc.
           Offering Statement on Form 1-A/A
           Filed on June 3, 2019
           File no. 024-10950

Dear Mr. Iglesias:

      We have reviewed your amended offering statement 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 this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your offering statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our April 3,
2019 letter.

Offering Statement on Form 1-A/A, filed on June 3, 2019

Dilution, page 26

1.    Net tangible book value is calculated by subtracting total liabilities
from total tangible
      assets. We note as of March 31, 2019 you had a net tangible deficit.
Please revise your
      calculations of net tangible book value/deficit and dilution accordingly,
and clearly
      indicate in your disclosures that you have a net tangible deficit, not
book value.
Financial Statements, page F-1

2.    We note your response to comment 4. Notwithstanding your intended use of
the proceeds
      from your offering, you are required under Rule 8-04 of Regulation S-X to
include in your
      filing the financial statements of businesses that are probable of being
acquired.
 Leandro Iglesias
iQSTEL Inc.
June 11, 2019
Page 2
General

3.    We note that, in response to prior comments 3 and 6, you have removed all
references to
      the acquisition of SwissLink Carrier AG from the offering circular
because no proceeds
      from the offering will be used to fund the acquisition. Please note that,
since the
      SwissLink acquisition appears to be material, you must disclose the
existence and terms of
      the definitive purchase agreement whether or not you use any offering
proceeds to fund
      the acquisition. Therefore, please revise to disclose the material terms
of the purchase
      agreement for SwissLink in an appropriate section of your offering
circular and file the
      agreement as an exhibit to the offering statement.
        You may contact Christie Wong, Staff Accountant, at 202-551-3684, or
Robert S.
Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Kathleen Krebs, Special Counsel, at 202-551-3350,
with any other
questions.



                                                          Sincerely,
FirstName LastNameLeandro Iglesias
                                                          Division of
Corporation Finance
Comapany NameiQSTEL Inc.
                                                          Office of
Telecommunications
June 11, 2019 Page 2
cc:       Scott Doney
FirstName LastName
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