September 19, 2024

Xavier Destriau
Chief Financial Officer
ZIM Integrated Shipping Services Ltd.
9 Andrei Sakharov Street
Matam, Haifa 3190500, Israel

       Re: ZIM Integrated Shipping Services Ltd.
           Form 20-F for the Fiscal Year ended December 31, 2023
           Filed March 13, 2024
           File No. 001-39937
Dear Xavier Destriau:

       We have reviewed your filing and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Fiscal Year ended December 31, 2023
Reports of Independent Registered Public Accounting Firms, page F-3

1.     We note that your principal auditor indicates the firm did not audit the
financial
       statements of your subsidiary ZIM American Integrated Shipping Services
Company,
       LLC, though has instead relied on the audit of FORVIS LLP with respect
to that entity.
       However, the audit opinion on page F-6 covers only the earliest two
fiscal years within
       the three year period for which financial statements are provided in
your filing.

       Therefore, it is unclear whether the audit work of your principal
auditor includes the more
       recent financial statements of the subsidiary or if there is continued
reliance on the work
       of the other auditor with regard to the subsidiary for all periods.
Please discuss this
       observation with your auditors and arrange to obtain and file a revised
audit opinion from
       the principal auditor that will clarify this matter and if there is
continued reliance also
       include the audit opinion from the other auditor that covers all
periods.

       Please refer to Instruction 2 to Item 8.A.2 of Form 20-F, Rule
2-02(a)(4) of Regulation S-
       X, and PCAOB AS 1206.08 if you require further clarification or
guidance.
 September 19, 2024
Page 2

        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.

       Please contact Joseph Klinko at 202-551-3824 or Karl Hiller at
202-551-3686 if you have
questions regarding comments on the financial statements and related matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Energy &
Transportation