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                                                           October 17, 2019

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

       Re: iQSTEL Inc.
           Amendment No. 5 to
           Offering Statement on Form 1-A
           Filed September 25, 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 June 11,
2019 letter.

Amendment No.5 to Form 1-A filed September 25, 2019

Management's Discussion and Analysis
Operating Expenses, page 8

1.    For six months ended June 30, 2019, please expand to discuss the
underlying factors that
      caused operating expenses with material changes i.e. Salaries, Wages and
Benefits,
      Professional fees and Advertising costs.
 Leandro Iglesias
FirstName LastNameLeandro Iglesias
iQSTEL Inc.
Comapany NameiQSTEL Inc.
October 17, 2019
October 17, 2019 Page 2
Page 2
FirstName LastName
Description of Business
Recently completion of Acquisition of SwissLink Carrier AG, page 24

2.       Please file the SwissLink acquisition agreement as an exhibit as well
as the material
         outstanding loans from the seller of SwissLink that are referenced in
the agreement and on
         page 24 of the offering circular.
Security Ownership of Certain Beneficial Owners and Management, page 37

3.       Please re-insert Metrospaces Inc. in the beneficial ownership table.
Consolidated Financial Statemetns as of and for Period Ended June 30, 2019
Notes to the Unaudited Consolidated Financial Statements
Note 13 - Subsequent Events , page F-29

4.       You indicated that you issued 187,500 shares for the 51% equity
interest of SwissLink
         Carrier AG in August, 2019. We further note in Exhibit 15.3 Unaudited
Pro Forma
         Financial Statements that you issued 343,512 shares of common stock
upon the closing of
         the transaction. Please explain the discrepancies and revise
accordingly.
Exhibit 15.2 Unaudited Financials for SwissLink Carrier AG for the Three Months
Ended March
31, 2019, page 41

5.       Please update and provide the unaudited interim financial statements
and related footnote
         disclosure of SwissLink Carrier AG as of and for the six months ended
June 30, 2019.
Exhibit 15.3 Unaudited Pro Forma Combined Financial Statements , page 41

6.       Please update to reflect the unaudited pro forma combined financial
statements as of and
         for the period ended June 30, 2019.
        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,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Scott Doney
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