March 25, 2019

Matias I. Gaivironsky
Chief Financial Officer
IRSA INVESTMENTS & REPRESENTATIONS INC
Moreno 877 24th Floor
Buenos Aires, Argentina

       Re: IRSA INVESTMENTS & REPRESENTATIONS INC
           Form 20-F for the fiscal year ended June 30, 2018
           Filed October 31, 2018
           Response Dated December 13, 2018
           File No. 001-13542

Dear Mr. Gaivironsky:

         We have limited our review of your filing to the financial statements
and related
disclosures, and have also reviewed your December 13, 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 November
20, 2018 letter.

Form 20-F for the fiscal year ended June 30, 2018

ITEM 5. Operating and Financial Review and Prospects
Effects of foreign currency fluctuations, page 148

1.    We understand that there have been no observable comparable shopping mall
transactions
      in a number of years, that your shopping mall valuation methodology
relies on a number
      of inputs that are not observable or readily estimable (e.g., long-term
Argentine inflation,
      peso discount rates and peso-dollar forward foreign exchange rates), and
that dislocations
      in the Argentine economy affect your valuation approach; please explain:
        How you considered the reliability of your shopping mall fair value
measurements and
          IAS 40.31 when changing from cost to fair value.
 Matias I. Gaivironsky
FirstName LastNameMatias I. Gaivironsky
IRSA INVESTMENTS & REPRESENTATIONS INC
Comapany2019
March 25, NameIRSA INVESTMENTS & REPRESENTATIONS INC
March 25, 2019 Page 2
Page 2
FirstName LastName
             How you determined that shopping mall fair values are reliably
measurable on a
             continuing basis as contemplated in IAS40.53.
2.       Your prior response to comment #1 indicates that the fluctuation in
shopping mall fair
         value is primarily attributable to an increase in real rents and a
decrease in the discount
         rate (i.e., reflecting changes in market participant views of shopping
mall risk).
           Explain the economic driver of growth in shopping mall real rents.
           Explain why office properties did not experience a similar growth in
real rents.
           Explain why office properties did not experience a similar
contraction in discount
             rates.
3.       As of June 30, 2016 and 2015, we observe that a financial data
aggregator published
         ARS/USD non-deliverable forward (NDF) rates for periods of 3 and 5
years, respectively;
         please explain:
           Why NDF rates are, or are not, relevant to the valuation of your
shopping malls.
           If excluding NDF rates is consistent with the IFRS 13 requirement to
maximize the
             use of observable inputs.
           How the use of NDF rates would affect your fair value measurements.
4.       Your response cites "macroeconomic imbalances" as a driver of shopping
mall
         appreciation; please explain:
           If the effect on the valuation is reflective of a shortcoming of
your valuation approach,
            and why or why not.
           If the effect on shopping mall valuations is the result of
inconsistent assumptions (e.g.,
            inconsistencies between the inflation rates used to forecast
shopping mall rents, and
            the inflation rates implicit in the peso-dollar forward rates).
           Why those imbalances did not affect office valuations.

5.       Your response notes that the risks of each specific shopping mall are
captured in your cash
         flow forecasts for each mall; please explain how your cash flow
forecasts capture the
         specific risks of each mall (e.g., scenario analysis).
6.       We understand that your WACC calculation includes an after-tax cost of
debt, and
         observe that your calculation includes inputs observed from U.S.
domiciled entities to
         determine the spread above the Argentine risk-free rate; please
explain:
           How the unadjusted applicable U.S. sector spread is reflective of
Argentine market
             participant assumptions.
           Why the U.S. statutory tax rate is reflective of Argentine shopping
mall market
             participant assumptions, and how market participants expectations
regarding tax law
             changes would or would not affect the use of the statutory rate.
           Why U.S. debt and equity weightings are reflective of Argentine
shopping mall market
 Matias I. Gaivironsky
IRSA INVESTMENTS & REPRESENTATIONS INC
March 25, 2019
Page 3
             participant assumptions.
             Why your WACC estimates are lower than those implied by use of
U.S. domiciled
             entity assumptions.
       In closing, 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 Eric McPhee at 202-551-3693 or Robert Telewicz at
202-551-3693
with any questions.



                                                           Sincerely,
FirstName LastNameMatias I. Gaivironsky
                                          Division of Corporation Finance
Comapany NameIRSA INVESTMENTS & REPRESENTATIONS INC
                                          Office of Real Estate and
March 25, 2019 Page 3                     Commodities
FirstName LastName