July 31, 2020

Re: Global Blue Group Holding AG (the “Company”)

Registration Statement on Form F-4, as amended

Filed February 24, 2020, June 19, 2020, July 8, 2020, July 17, 2020 and July 23, 2020

File No. 333-236581 (the “Registration Statement”)

Ms. Christine Dietz

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, DC 20549-3628

cc: Mr. Jeff Kauten

Dear Chris:

This letter is in response to your request from our call on July 30, 2020, for some further information regarding the recoverable amount/goodwill figures for the Staff’s Comment 3 from the Staff’s letter of July 27, 2020. The Company’s response is below.

• As noted in the response letter dated July 30, 2020, the Company had within the July 20, 2020 letter provided the headroom by which the recoverable amount of the CGU less net debt exceeded the carrying value of the goodwill (“Method 1”). Upon clarification of the Staff’s question in the letter dated July 23, 2020, the Company provided the recoverable amount for each of the CGUs relative to the carrying value (including goodwill) of the CGU (“Method 2”)

• To assist with the Staff’s review, please see attached a summary table summarizing the headroom (€K and %), per method, for both the central case and the negative growth sensitivity

BEIJING HONG KONG HOUSTON LONDON LOS ANGELES PALO ALTO SÃO PAULO TOKYO WASHINGTON, D.C.

		Simpson Thacher & Bartlett LLP
Christine Dietz	-2-	July 31, 2020

• While the conclusion remains unchanged, the numbers are not entirely comparable, as clarified below:

o In Method 1, the FV of the CGU is after the deduction of the net debt; whereas, in Method 2, the FV of the CGU was not accordingly reduced for net debt

o When comparing the negative growth sensitivity to the central case, while the FV of the CGU reduction is the same in both methodologies, due to the net debt being constant (i.e. not impacted by the sensitivity), the magnitude of the decline in the FV of the CGU (less net debt) in Method 1 is larger

With regard to Staff comment 4, we propose to cover the additional footnote disclosure you requested in Note 17 (Goodwill), instead of subsequent events, because it is not a subsequent event, but rather is due to using available information through when the financial statements are issued.

Please let us know if a further discussion would be helpful.

Thanks again for your consideration,

/s/ Michael Wolfson

Michael Wolfson

cc: Far Point Acquisition Corporation

Global Blue Group Holding AG

Morgan, Lewis & Bockius LLP

(€K)	Central Case														Negative 2.5% Sensitivity
JULY 20TH ANALYSIS (“Method 1”)
	FV of CGU		Net Debt			FV of CGU (less net debt)		Goodwill of CGU		Headroom		% Goodwill			FV of CGU		Net Debt			FV of CGU (less net debt)		Goodwill of CGU		Headroom		% Goodwill
TFS		1,446,475		(442,318	)		1,004,157		358,760		645,397		180	%		833,299		(468,141	)		365,158		358,760		6,398		2	%
AVPS		327,731		(100,217	)		227,514		49,200		178,314		362	%		132,422		(74,394	)		58,028		49,200		8,828		18	%
Total		1,774,206		(542,535	)		1,231,671		407,960		823,711		202	%		965,721		(542,535	)		423,186		407,960		15,226		4	%
Memo: Net debt allocated based on the proportional split of the FV of CGU per case
JULY 24TH ANALYSIS (“Method 2”)
	FV of CGU							Carrying Value of CGU (incl. Goodwill)		Headroom		% Carrying Value (incl. Goodwill)			FV of CGU							Carrying Value of CGU (incl. Goodwill)		Headroom		% Carrying Value (incl. Goodwill)
TFS		1,446,475							671,351		775,124		115	%		833,299							671,351		161,948		24	%
AVPS		327,731							104,086		223,645		215	%		132,422							104,086		28,336		27	%
Total		1,774,206							775,437		998,769		129	%		965,721							775,437		190,284		25	%