June 14, 2019

Laila Cecilie Halvorsen
Chief Financial Officer
DHT Holdings, Inc.
Clarendon House
2 Church Street, Hamilton HM11
Bermuda

       Re: DHT Holdings, Inc.
           Form 20-F for the Year Ended December 31, 2018
           Filed March 28, 2019
           File No. 001-32640

Dear Ms. Halvorsen:

       We have reviewed your filing 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 Year Ended December 31, 2018

Item 5. Operating and Financial review and Prospects
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies
Carrying Value and Impairment, page 36

1.    We note your disclosure on page 37 that in 2017 you performed an
impairment analysis
      on each vessel and the rates used were 1) the current FFA for the first
two years and 2) the
      25-year historical average spot earnings as reported by Clarksons
Shipping Intelligence
      thereafter. In light of the fact that these rates appear to differ from
those used in the 2016
      impairment analysis, please tell us, and revise to explain in your
critical accounting policy
      discussion, the reason for the changes in rates for years 1-3 and
thereafter. As part of your
      response, please provide us the following information:
        Tell us how this change relates to your assertion of industry and rate
cyclicality
 Laila Cecilie Halvorsen
FirstName LastNameLaila Cecilie Halvorsen
DHT Holdings, Inc.
Comapany NameDHT Holdings, Inc.
June 14, 2019
Page 2
June 14, 2019 Page 2
FirstName LastName
             through the years;
             What was the source of the 10 year average one year time charter
rate and if it
             Clarkson's, please explain the reason for the change in source;
             Tell us how the FFA rate used for the first two years of the
analysis compares to the
             Company's current spot rates;
             How does the 25 year average spot rate compare to the 10 year
average one year time
             charter rate for 2018, 2017 and 2016;
             Also, please explain to us your basis for using a 20% rate haircut
for vessels over 15
             years of age and how that compares to historical results.


2.       We note that in the fourth quarter of 2017 you adjusted the carrying
value of your fleet
         through a non-cash impairment charge totaling $7.9 million and a
reversal of prior
         impairment totaling $7.4 million. For the vessels in which you
reversed the prior
         impairment charges, please tell us the events and circumstances that
led to the reversal.
         As part of your response, please clearly tell us why you believe the
estimated service
         potential of the assets has increased. See paragraphs 110-116 of IAS
36.
3.       We note your disclosure on the top of page 39 that in aggregate, the
carrying value of your
         vessels as of December 31, 2018 was above the charter-free fair market
value by
         approximately $8.1 million. Please also disclose the aggregate
carrying and charter-free
         fair market values with respect to those vessels having carrying
values that exceed their
         charter-free market values.
Results of Operations, page 39

4.       We note your disclosures regarding the factors for which fluctuations
in income statement
         line items are attributed; however, in addition to discussing the
reasons for the change (or
         lack thereof), please also quantify the reasons for the change,
particularly when more than
         one factor is attributed to the change. For example, you state that
certain increases were
         "primarily" attributed to one factor, and "partially offset" by
another factor, or, you
         indicate, that "additionally", an increase was attributed to more than
one factor without
         quantifying each. For a company with the size and breadth of
operations as yours, these
         disclosures should be presented in a manner so as to allow investors
to discern the relative
         contribution of each of the multiple components cited to the total
change. Please revise to
         separately quantify each significant factor-such as fleet size changes
and rate
         increases/decreases contributing to the change for each of the line
items discussed within
         the results of operations section. As part of your response, please
provide us with an
         example of the disclosure to be included in future filings.
        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.

         You may contact Effie Simpson at (202) 551-3346 or Claire Erlanger at
(202) 551-3301
 Laila Cecilie Halvorsen
DHT Holdings, Inc.
June 14, 2019
Page 3

if you have questions regarding comments on the financial statements and
related
matters. Please contact Melissa Raminpour, Branch Chief at (202) 551-3750 with
any other
questions.



FirstName LastNameLaila Cecilie Halvorsen                Sincerely,
Comapany NameDHT Holdings, Inc.
                                                         Division of
Corporation Finance
June 14, 2019 Page 3                                     Office of
Transportation and Leisure
FirstName LastName