CORRESP 1 filename1.txt Mr. William Choi Guy Thomson Branch Chief, Division of Vice President Accounting & Reporting Corporation Finance P.O. Box 985, 1000 AZ Amsterdam Securities and Exchange Commission Piet Heinkade 167-173 101 F Street N.E. 1019 GM Amsterdam Washington, D.C. 20549-3561 The Netherlands U.S.A. Phone + 31 (0)20 509 5100 Fax + 31 (0)20 509 5110 DATE: February 9, 2007 Re: ROYAL AHOLD FORM 20-F FOR THE FISCAL YEAR ENDED JANUARY 1, 2006 FILED APRIL 13, 2006 SEC FILE NO. 1-2510 Dear Mr. Choi: This is in response to the Staff's comment letter dated February 6, 2007 (the " Response Comment Letter"), responding to the response letter of Koninklijke Ahold N.V. ("Ahold" or the "Company") to the Staff's comment letter dated December 29, 2006 relating to the Annual Report on Form 20-F for the fiscal year ended January 1, 2006 (the "2005 20-F"). Set forth below is the response of the Company to the Staff's comment in the Response Comment Letter. For ease of reference, the comment contained in the Response Comment Letter is printed below in bold and is followed by the Company's response. Consolidated Statements of Cash Flows, page 90 1. We have reviewed your response to comment 2 in our letter dated January 1, 2007. We continue to believe that "profit and loss" as contemplated by paragraph 20 of IAS 7 should be based upon the measure of "profit and loss" described in paragraphs 78 and 79 of IAS 1. Therefore, it appears that you should begin your reconciliation of net cash flows from operating activities with net income as opposed to operating income. Please revise your presentation with retrospective application to all periods presented in future filings. Ahold Response In response to the Staff's comment we will comply with the Staff's request to revise the presentation of our net cash flows from operating activities. We will begin the reconciliation with net income and include the revised presentation in future filings, starting with our 2006 Annual Report to be filed on Form 20-F by the end of March, with retrospective application to all periods presented therein. We trust that our response adequately addresses the Staff's comment and respectfully request that the Staff advise us at its earliest convenience if the Staff believes that the response set forth in this letter is incomplete Koninklijke Ahold N.V. Trade Register Amsterdam No. 35000363 ABN AMRO Amsterdam 48.60.29.875 or unsatisfactory or if the Staff has any further comments on our filings. If the Staff wishes to discuss the response provided, please do not hesitate to contact me at +31-20-509-5147, Alfred Popken of Deloitte & Touche LLP at +1-212-436-3693 or David Johansen of White & Case LLP at +1-212-819-8509. Sincerely, /s/ Guy Thomson --------------- Guy Thomson Vice President Accounting & Reporting Cc: Mr. Andrew Blume, SEC, Division of Corporation Finance, Staff Accountant Mr. David Johansen, White & Case LLP, New York Mr. Alfred Popken, Deloitte & Touche LLP, New York Mr. Eric Hespenheide, Deloitte & Touche LLP, Detroit Mr. Marco van der Vegte, Deloitte Accountants b.v., Amsterdam