CORRESP 1 filename1.txt VIA EDGAR AND FACSIMILE Mr. Larry Spirgel June 22, 2007 Assistant Director Division of Corporation Finance United States Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549 USA Re: British Telecommunications plc Form 20-F for the Fiscal Year Ended March 31, 2006 File Number: 2-94004 Dear Mr. Spirgel, The following responds to your comment as set forth in the telephone conversation on June 15, 2007 with Kathryn Jacobson of the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") regarding the above-referenced filing. As of the above date we have also separately responded to the Staff's comment in respect of the Form 20-F filing for BT Group plc for the fiscal year ended March 31, 2006. The Staff's comment is highlighted in bold and italics below followed by British Telecommunications plc's (the "company") response. Form 6-K as of May 31, 2006 Annual Report Group balance sheet, page 38 1. We note your response to prior comment 2; in future filings please discuss in the MD&A what the sub total "total assets less current liabilities" represents and why it is meaningful to your investors. Refer to para 69 of IAS 1. We note the above comment and will include further disclosure in the MD&A in our future filings. As we previously noted, IAS 1, paragraph 69 allows the presentation of additional line items, headings and sub-totals on the face of the balance sheet when such presentation is relevant to an understanding of the entity's financial position. We continue to believe it is appropriate to show the sub-total "Total assets less current liabilities" in the group balance sheet because it provides useful financial information being an indication of the level of the capital employed at the balance sheet date, namely total equity and non current liabilities. We believe this information is important to our shareholders, investors and other stakeholders as this balance sheet presentation has been consistently used for many years under UK GAAP prior to our adoption of IFRS. ________________________________________________ In connection with our response to your comment the company acknowledges that: o It is responsible for the adequacy and accuracy of the disclosures in the filings; o Staff comments, or changes to disclosure in response to Staff comments, do not foreclose the Commission from taking any action with respect to the filings; and o It may not assert Staff comments as a defence in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Should you have any questions or comments regarding our responses please call me at + 44 20 7356 5511 or John Wroe, Director Group Financial Control and Treasury at + 44 20 7356 4963. Yours sincerely, /s/ Hanif Lalani OBE (Order of the British Empire) Group Finance Director Copies to: British Telecommunications plc John Wroe Glyn Parry PricewaterhouseCoopers LLP Charles Bowman (Engagement audit partner)