June 16, 2006

Mail Stop 4561

By U.S. Mail and facsimile to 011-81-3-5419-5901

Shunsuke Takeda
Vice Chairman and Chief Financial Officer
ORIX Corporation
Mita NN Bldg, 4-1-23 Shiba, Minato-Ku
Tokyo, 108-0014, Japan


Re:	ORIX Corporation
	Form 20-F filed July 15, 2005
	File No. 001-14856

Dear Mr. Takeda:


	We have reviewed your response letter dated June 5, 2006 and
have the following comments.  Where indicated, we think you should
revise your document in future filings in response to these
comments.
If you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In our comments we ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.












Form 20-F for Year ended March 31, 2005

Financial Statements for the period ending March 31, 2005

Consolidated Statements of Income, page F-5

1. We refer to your response to Comment 1.  Please consider
providing
in your 20-F for the year ended March 31, 2006 the following
information as part of your disclosure in Note 30, "Segment
Information":

a. Describe the methodology used to allocate compensation costs
currently included in the selling, general and administrative
expenses line item in the Consolidated Statement of Income that
are
directly related to the revenue generating activities of each
operating segment.

b. Provide a separate line item within the financial results of
each
operating segment for the compensation costs related directly to
the
revenue producing activities of that segment that have been
allocated
from consolidated selling, general and administrative expenses.

2. In future filings, please revise the "Results of Operations"
section of Item 5, "Operating and Financial Review and Prospects"
to
provide a discussion of the following:

a. How your income statement presentation is structured based on
your
diversified operating activities that constitute your core
operations
related to corporate finance, real estate businesses, life
insurance,
retail finance and overseas operations.

b. How you have included your lending and investing activities in
the
income statement in a format similar to those of banking
institutions
consistent with the presentation of these activities required by
Article 9 of Regulation S-X.

c. How you have presented the various revenue accounts that
constitute significant operating revenues of your core business
activities and their directly related expenses in a manner
consistent
with the disclosure guidelines of Article 5.03 of Regulation S-X,
including your consideration of material non-recurring revenue
streams and expenses, such as writedowns of long-lived assets and
investments in securities.

d. How you determined that the revenues and expenses included in
Other Operating Expense and Other Operating Revenues are to be
considered a part of your recurring operating activities.



*	*	*


Closing Comments

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.   You may wish
to
provide us with marked copies of your proposed changes to
disclosure
in future filings to expedite our review. Please understand that
we
may have additional comments after reviewing your responses to our
comments.

      You may contact Edwin Adames (Senior Staff Accountant) at
(202)
551-3447 or me at  (202) 551-3490 if your have any questions
regarding these comments.


						Sincerely,



						Donald A. Walker
						Senior Assistant Chief Accountant
Shunsuke Takeda
ORIX Corporation
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