Mailstop 3233
                                                                  November 20,
2018


     Via E-Mail
     Matias I. Gaivironsky
     Chief Financial Officer
     IRSA Inversiones y Representaciones Sociedad An nima
     Moreno 877 24th Floor
     Buenos Aires, Argentina

            Re:     IRSA Inversiones y Representaciones Sociedad An nima
                    Form 20-F for the fiscal year ended June 30, 2017
                    Filed October 31, 2017
                    Response Dated October 19, 2018
                    File No. 001-13542

     Dear Mr. Gaivironsky:

            We have reviewed your October 19, 2018 response to our comment
letter 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.
     Unless we note otherwise, our references to prior comments are to comments
in our September
     21, 2018 letter.

     Form 20-F for the fiscal year ended June 30, 2017

     Item 5. Operating and Financial Review and Prospects

     Critical Accounting Policies and Estimates, page 141

     Effects of foreign currency fluctuations, page 145

     1.     We understand that rents from your shopping mall leases are indexed
to tenant revenues,
            that you expect tenant revenue growth to be correlated to Argentine
inflation, and that
            you attribute the appreciation in shopping mall fair values
relative to office fair values to
            those expectations. Please quantify the effect of indexed rents on
your shopping mall fair
 Matias I. Gaivironsky
IRSA Inversiones y Representaciones Sociedad An nima
November 20, 2018
Page 2

      value measurements. Please explain how the increase in nominal cash flows
due to
      indexed rents is, or is not, offset by the use of a nominal discount
rate.

2.    We understand that you do not determine the discount rate implied by the
fair value of
      your office properties for which fair value is measured using comparable
transactions.
      IFRS 13 requires maximization of relevant observable inputs; please
explain why the
      discount rate for office properties is not relevant for measuring the
fair value of other
      commercial investment properties, such as shopping malls.

3.    We understand that you consider your weighted-average cost of capital
(WACC) when
      discounting future cash flows to measure the fair value of your shopping
malls. Please
      explain:
             why your WACC is consistent with market participant assumptions;
and
             How your WACC is adjusted for different risks associated with each
investment
             property.

4.    If the discount rate for office properties is not relevant to the fair
value measurement of
      shopping mall properties, please explain why it is appropriate to use
your enterprise
      WACC to discount the future cash flows of your shopping mall properties.
That is, since
      you hold both shopping mall properties and office properties, if you
believe that shopping
      mall discount rates are not relevant to shopping malls, explain why your
WACC would
      be appropriate for shopping malls.

5.    We understand that you use forward USD/ARS forward rates implied by the
onshore
      futures market for one year to measure the fair value of your shopping
malls, and then
      revert to long-term relative inflation rates in the two currencies.
Please explain how you
      consider other observable sources for forward foreign exchange rates. For
example, we
      observe that certain financial data aggregators publish estimated
non-deliverable forward
      foreign exchange rates for periods up to five years at certain valuation
dates.

       You may contact Eric McPhee at (202) 551-3693 or me at (202) 551-3438
with any
questions.


                                                            Sincerely,

                                                            /s/ Robert F.
Telewicz, Jr.

                                                            Robert F. Telewicz,
Jr.
                                                            Branch Chief
                                                            Office of Real
Estate and
                                                             Commodities