Mailstop 3233
                                                                September 21,
2018


     Via E-Mail
     Matias I. Gaivironsky
     Chief Financial Officer
     IRSA Propriedades Comerciales S.A.
     Moreno 877 22nd Floor
     Buenos Aires, Argentina

            Re:    IRSA Propriedades Comerciales S.A.
                   Form 20-F for the fiscal year ended June 30, 2017
                   Filed October 10, 2017
                   Response Dated August 15, 2018
                   File No. 000-30982

     Dear Mr. Gaivironsky:

            We have reviewed your August 15, 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 July 23,
     2018 letter.

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

     Item 5. Operating and Financial Review and Prospects

     A. Operating Results

     Results of operations for the fiscal years ended June 30, 2017 and 2016

     Changes in fair value of investment property, page 122

     1.     We have reviewed your response to comment 2. Please tell us the
underlying market or
            economic factors that caused the significant increases in the
values of your shopping mall
 Matias I. Gaivironsky
IRSA Propriedades Comerciales S.A.
September 21, 2018
Page 2

       properties relative to your other property types. Please note that while
changes in
       methodologies or assumptions for internal calculations utilizing
unobservable inputs may
       impact your estimate of fair value, fair value, in accordance with IFRS
13, is the actual
       price that would be received to sell an asset in an orderly transaction
between market
       participants at a given measurement date. To the extent you believe that
market and/or
       economic changes uniquely impacted the value which market participants
would be
       willing to pay for shopping mall properties versus other property types,
please specify
       those factors and explain why they have impacted the price of shopping
mall properties
       relative to other property types.

2.     We note from your June 11, 2018 response that you translate the
peso-denominated
       projected cash flows of your shopping mall properties into US dollars
using projected US
       dollar-peso exchange rates for the periods involved. Please tell us what
periods were
       included in your projections, the forward US dollar-peso exchange rates
you used for
       each of those periods, and how you determined those forward exchange
rates. In your
       response, please compare the forward US dollar-peso exchange rates to
the spot rates at
       the respective balance sheet dates and, in addition, please confirm you
are able to obtain
       forward exchange rates for periods greater than 12 months into the
future.

3.     We note from your response to comment 2 that there is no observable data
available to
       estimate a long-term peso-denominated interest rate with which to
discount the projected
       future cash flows of your assets. Please clarify how you determined that
reliable forward
       US dollar-peso exchange rates can be estimated and what factors cause
you to be unable
       to estimate a long-term peso-denominated discount rate.

       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