Mail Stop 3561                                             August 24, 2018


Mr. Daniel H. Schulman
President and Chief Executive Officer
2211 North First Street
San Jose, California 95131

       Re:    PayPal Holdings, Inc.
              Form 10-K for Fiscal Year Ended December 31, 2017
              Filed February 7, 2018
              Form 10-Q for Fiscal Quarter Ended June 30, 2018
              Filed July 26, 2018
              File No. 001-36859

Dear Mr. Schulman:

        We have reviewed your filings 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 10-Q for the Quarter Ended June 30, 2018

Financial Statements

Note 2   Revenue

Transaction Revenue, page 10

   1. We note you have determined that your transaction revenue represents a
single
      performance obligation. Please tell us each promised good or service you
have identified
      in these arrangements. In addition, provide us your analysis regarding
how you
      determined that all goods and services in these arrangements should be
combined.
      Reference 606-10-25-19 through 22.

   2. Your disclosure indicates that transaction fees collected from your
customers are
      recognized as revenue on a gross basis because you are the principal in
respect of
 Mr. Daniel H. Schulman
PayPal Holdings, Inc.
August 24, 2018
Page 2

       processing payments. Please describe the services provided by each party
involved in the
       payment processing transaction and tell us how you determined you
control each service
       before it is transferred to the customer. Reference ASC 606-10-55-36
through 40.

Note 17   Restructuring, page 33

    3. We note the restructuring charges in the first half of 2018 include
charges related to your
       decision to wind down TIO's operations. We also note your disclosures
about the
       intangible assets and net assets recognized in July 2017 upon
acquisition of this business
       and the $30 million impairment of customer related intangible assets
recognized during
       the fourth quarter of 2017 upon the suspension of TIO's operations. In
light of your
       decision to wind down TIO's operations, please tell us how you
considered whether any
       of the remaining tangible and intangible assets of this business may be
impaired. We
       may have further comment after reviewing your response.

        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 Sondra Snyder, Staff Accountant at (202) 551-3332 or me
at (202) 551-
3737 with any questions.


                                                             Sincerely,

                                                             /s/ Jennifer
Thompson

                                                             Jennifer Thompson
                                                             Accounting Branch
Chief
                                                             Office of Consumer
Products