Mail Stop 3720

Via US Mail & Fax 27 12 311 8769
      April 21, 2006

Mr. Sizwe Nxasana, Chief Executive Officer
Telekom SA Limited
152 Pretoria Street
Pretoria, South Africa, 0002


	Re:  	Telekom SA Limited
      Form 20-F for the year ended March 31, 2005
      Filed on July 15, 2005
		File No. 1-31609

Dear Mr. Nxasana:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Please address the following comment
in
future filings.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In our comment, we may ask you to provide us with information so
we
may better understand your disclosure.  After reviewing this
information, we may or may not 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 comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


*   *   *   *   *





Telekom SA Limited
April 21, 2006
Page 2



Accounting comments:

Notes to the consolidated annual financial statements

Note 2. Significant accounting policies

Note 5.6 Depreciation, amortization, impairment and write-offs,
page
F-31

1. We note that there may be differences in the methods of
assessing
and measuring impairment of long-term assets under IFRS and US
GAAP.
Tell us how you applied the guidance in SFAS 144 in determining
the
amount of the impairment loss for intangible assets and property,
plant and equipment for US GAAP reporting.

Note 45. Investments in joint ventures, page F-99

2. Consider disclosing the significant provisions of the Vodacom
joint venture agreement in the notes to the financial statements
to
demonstrate how you meet the criteria in IAS 31 to use the
proportionate consolidation method of accounting.   Also tell us
whether you have provided all the applicable disclosures in
paragraphs 54 through 57 of IAS 31.

Note 47. US GAAP Information, page F-100

(a) Revenue recognition, page F-106

3. You disclose at page F-24 that revenue from sale of the handset
is
recognized when the product is delivered. Please tell us how you
recognize revenue under US GAAP.  For example, tell us how you
applied the guidance in paragraph 14 of EITF 00-21 that limits the
amount of consideration allocated to a deliverable to the amount
that
is not contingent on the delivery of additional items or future
services.

4. Tell us how the differences in accounting for revenue earned
from
installation and activation fees result in an increase in earnings
in
the reconciliation to US GAAP at page F-101.  Since revenues from
installation and activation are deferred for US GAAP reporting, it
appears that net income would decrease.   Also since you revised
your
revenue recognition policy in 2005 to defer activation revenue and
costs as disclosed at page F-9, it is unclear why there is a
difference in results of operations for 2005.






Telekom SA Limited
April 21, 2006
Page 3


Vodacom Group Financial Statements

Note I .Revenue Recognition

Note I.1 Contract Products, page F-137

5. You disclose that revenue from sale of the handset in an
arrangement with multiple deliverables is recognized when the
product
is delivered. Please tell us how you recognize revenue under US
GAAP.
For example, tell us how you applied the guidance in paragraph 14
of
EITF 00-21 that limits the amount of consideration allocated to a
deliverable to the amount that is not contingent on the delivery
of
additional items or future services.

Note Q Incentives, page F-144

6. Tell us how you applied the guidance in EITF 01-9 in
determining
the US GAAP accounting treatment for incentives paid to service
providers and dealers for new activations and retention of
existing
customers.

Note 3 Impairment of Assets, page F-145

7. We note that there may be differences in the methods of
assessing
and measuring impairment of long-term assets under IFRS and US
GAAP.
Tell us how you applied the guidance in SFAS 144 in determining
the
amount of the impairment loss for intangible assets and property,
plant and equipment for US GAAP reporting.

*   *   *   *   *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR.  Please understand that
we
may have additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.



Telekom SA Limited
April 21, 2006
Page 4

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.



      	You may contact Gopal Dharia, Staff Accountant, at (202)
551-3353 or Terry French, Accountant Branch Chief, at (202) 551-
3828
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

									Sincerely,


									Larry Spirgel
									Assistant Director