United States securities and exchange commission logo





                              September 2, 2021

       Cyrus Madon
       Chief Executive Officer
       Brookfield Business Partners L.P.
       73 Front Street
       Hamilton, HM 12
       Bermuda

                                                        Re: Brookfield Business
Partners L.P.
                                                            Form 20-F for the
year ended December 31, 2020
                                                            Filed March 17,
2021
                                                            File No. 001-37775

       Dear Mr. Madon:

              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, 2020

       Use of Non-IFRS Measures, page 5

   1.                                                   Your calculation of
Company EBITDA contains adjustments for items other than interest,
                                                        taxes, depreciation and
amortization. In future filings please revise the title of this non-
                                                        IFRS measure, such as
"Adjusted EBITDA," to distinguish it from EBITDA as commonly
                                                        defined. Likewise,
please revise the title of your Company FFO non-IFRS measure. Refer
                                                        to Question 103.01 of
the Compliance and Disclosure Interpretations on Non-GAAP
                                                        Financial Measures.
       Risks associated with the Covid-19 pandemic, page 12

   2.                                                   We note your disclosure
of potential adverse impacts from COVID-19 in the risk factors
                                                        section on page 12.
Please tell us what consideration you gave to providing expanded
                                                        information regarding
specific impacts that your business has experienced from the
 Cyrus Madon
FirstName
Brookfield LastNameCyrus
           Business PartnersMadon
                             L.P.
Comapany 2,
September  NameBrookfield
              2021          Business Partners L.P.
September
Page 2     2, 2021 Page 2
FirstName LastName
         COVID-19 pandemic (e.g. quantifiable impacts to your scaffolding
services and
         automotive battery businesses during 2020 which might address impacts
to revenues or
         service/product order cancellations as well as impairments to assets
and other impacts to
         your liquidity, etc.). Refer to CF Disclosure Guidance: Topic No. 9
for additional
         guidance.
Reconciliation of Non-IFRS Measures, page 86

3.       We note your reconciliation of Company EBITDA and Company FFO,
non-IFRS
         measures, to the most directly comparable IFRS measure, which appears
to be in the form
         of a full non-GAAP income statement and gives greater prominence to
the non-IFRS
         measures. Please revise your presentation to instead provide separate
reconciliations from
         the most directly comparable IFRS measure, which appears to be Net
income (loss), to
         each of your non-IFRS measures and provide disclosure explaining the
nature of each
         adjustment and why you reflect each adjustment in your
reconciliations. Refer to Question
         102.10 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial
         Measures.
Consolidated Statements of Operating Results, page F-7

4.       It appears that you have presented your expenses by function, except
for Depreciation and
         amortization expense, which appears to be presented by the nature of
the expense. Please
         support you presentation under IAS 1 or present all of your expenses
by function and
         present a measure of Direct operating costs that is complete. Please
refer to paragraphs 15,
         29, 99 and 103 of IAS 1. We also note your presentation of the
components of Direct
         operating costs in Note 21 that presents amounts that are both by
function and by nature.
         Please revise your footnote disclosure to present the components of
Direct operating costs
         by nature.
Notes to Consolidated Financial Statements
Note 28. Segment Information, page F-79

5.       We note that you present several segment measures of profit or loss,
including Company
         EBITDA and Company FFO. Please tell us how your presentation of more
than one
         measure of segment profit or loss complies with the guidance in
paragraph 26 of IFRS 8.
        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 Howard Efron, Staff Accountant, at (202) 551-3439 or
Isaac Esquivel,
Staff Accountant, at (202) 551-3395 if you have questions regarding comments on
the financial
statements and related matters. Please contact Christopher Dunham, Staff
Attorney, at
(202) 551-3783 or Brigitte Lippmann, Staff Attorney, at (202) 551-3713 with any
other
questions.
 Cyrus Madon
Brookfield Business Partners L.P.
September 2, 2021
Page 3




FirstName LastNameCyrus Madon                    Sincerely,
Comapany NameBrookfield Business Partners L.P.
                                                 Division of Corporation
Finance
September 2, 2021 Page 3                         Office of Real Estate &
Construction
FirstName LastName