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                             April 17, 2024

       Torstein Hagen
       Chief Executive Officer and Chairman of the Board
       Viking Holdings Ltd
       94 Pitts Bay Road
       Pembroke, Bermuda HM 08

                                                        Re: Viking Holdings Ltd
                                                            Registration
Statement on Form F-1 filed April 5, 2024
                                                            Amendment No. 1 to
Form F-1
                                                            Filed April 15,
2024
                                                            File No. 333-278515

       Dear Torstein Hagen:

                                                        We have reviewed your
registration statement and have the following comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies to your
facts and circumstances
       or do not believe an amendment is appropriate, please tell us why in
your response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.

       Registration Statement on Form F-1

       Board Composition, page 140

   1.                                                   We note the new
disclosure regarding the individuals determined by your board of
                                                        directors to be
independent directors. Please expand the discussion to explain briefly how
                                                        Mr. Fear's role as a
director of your "principal shareholder" was considered in
                                                        reaching such
determination.
       Investor Rights Agreement -- Rights of Appointment, Consent Rights and
Registration Rights,
       page 149

   2.                                                   Please expand your
discussion of the Investor Rights Agreement to discuss the restrictions
                                                        on transfers included
in Section 4 of the Investor Rights Agreement filed as Exhibit 4.2.
                                                        Please also include
appropriate risk factor disclosure.
 Torstein Hagen
Viking Holdings Ltd
April 17, 2024
Page 2
Exhibits

3.       Please file any amendments or supplements to your Memorandum of
Association. In that
         regard, we note that Exhibit 3.1 refers to the company as "MISA
Investments Limited."
General

4.       We note your Form of Bye-laws filed as Exhibit 3.3 includes an
exclusive forum
         provision in section 77. Please revise your prospectus to provide
disclosure regarding this
         provision in the Risk Factors and Description of Share Capital
sections, including that the
         bye-laws expressly state that unless Viking consents in writing, the
sole and exclusive
         forum for any action asserting claims arising under the Securities Act
of 1933 or
         the Exchange Act of 1934, to the fullest extent permitted by
applicable law, shall be the
         United States federal district courts.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Jenifer Gallagher at 202-551-3706 or Karl Hiller at
202-551-3686 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Timothy S. Levenberg at 202-551-3707 or Karina Dorin at 202-551-3763
with any other
questions.



FirstName LastNameTorstein Hagen                              Sincerely,
Comapany NameViking Holdings Ltd
                                                              Division of
Corporation Finance
April 17, 2024 Page 2                                         Office of Energy
& Transportation
FirstName LastName