
		October 19, 2007

VIA HAND DELIVERY

Rufus Decker

Accountant Branch Chief

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-7010

Re:

Masisa S.A.

Annual Report on Form 20-F for the fiscal year ended December 31, 2006

Filed July 17, 2007

File No. 001-32555

Dear Mr. Decker:

Set forth below are the responses of Masisa to the Staff’s comments on Masisa’s Annual Report on Form 20-F for the fiscal year ended December 31, 2006, as filed with the Commission on July 17, 2007 (the “Masisa Form 20-F”). Capitalized terms used in this letter without definition have the meanings specified in the Form 20-F. For your convenience, we have repeated below in italics the Staff’s comments immediately prior to the responses of Masisa.

General

Where a comment below requests additional disclosures or other revision to be made, please show us in your supplemental response what the revisions will look like. Some of our comments refer to US GAAP literature. If your accounting under Chilean GAAP differs from your accounting under US GAAP, please also show us the additional disclosures that will be included in your US GAAP reconciliation footnote. These revisions should be included in your future filings.

We have addressed all the Staff comments included within your letter, and where a comment requests additional disclosures or other revision to be made, we have detailed in the response what the revisions will look like. All the Staff comments will be noted and considered in our future fillings.

Operating and Financial Review and Prospects

Contractual Obligations, page 83

Please revise your table of contractual obligations to disclose the assumptions made to derive amounts disclosed as interest debt payments. Please also revise to include contractual obligations associated with new plant construction projects and payments due in connection with your hedging contracts.

We shall disclose in future filings the assumptions made to derive the amounts disclosed as interest debt payments as follows:

“1) Interest debt payments include payments on contractual obligations outstanding as of December 31, 2006. Interest payments that might originate in the future from new debt obligations or debt refinancing after such date have not been considered.

2) For variable rate debt, interest payments were calculated using a weighed average Libor of 3.36%.

3) Payments denominated in currencies other than the US dollar were calculated using December 31, 2006 exchange rates.”

In addition, we shall include payments due in connection with hedging contracts in future filings, as follows:

		Total		Less than 1 year		1-3 years		3-5 years		more than 5 years
Hedging contracts		7,784		2,797		3,625		116		1,246

We would like to bring to the Staff’s attention that as of December 31, 2006 we do not hold any contractual obligations associated with new plant construction projects. To the extent that in the future we incur any such obligations we will disclose those amounts separately.

Consolidated Financial Statements

Note 2 - Summary of Significant Accounting Policies. Page F-8

3.	Please disclose your accounting policy for shipping and handling costs. Please refer to EITF 00-10

In response to the Staff’s comment, we shall disclose in future filings our accounting policy for shipping and handling costs in note 2 - Summary of Significant Accounting Policies, as follows:

“The Company records its shipping and handling costs within selling and administrative expenses. Shipping and handling costs mainly include transportation, warehousing and customs expenses.”

In addition, we shall disclose total shipping and handling costs in the financial statement footnotes as follows:

“As of December 31, 2006, 2005 and 2004, shipping and handling costs amounted to ThUS$22,690, ThUS$24,287 and ThUS$19,964 respectively.”

Please disclose the types of expenses that you include in the cost of sales line item and the types of expenses that you include in the selling expenses and general and administrative expenses line items. Please also disclose whether you include inbound freight charges, purchasing and receiving costs, inspection costs, warehousing costs, internal transfer costs, and the other costs of your distribution network in the cost of sales line item. With the exception of warehousing costs, if you currently exclude a portion of these costs from cost of sales, please disclose:

In a footnote the line items that these excluded costs are included in and the amounts included in each line item for each period presented, and

In MD&A that your gross margins may not be comparable to those of other entities, since some entities include all of the costs related to their distribution network in cost of sales and others like you exclude a portion of them from gross margin, including them instead in a line item, such as general and administrative expenses.

In response to the Staff’s comments, we shall provide disclosure in future filings in Note 2 - Summary of Significant Accounting Policies included in our Consolidated Financial Statements as follows.

“Our costs of sales include raw materials, labor costs, amortization, depreciation, outsourcing, electricity, fuel, personnel benefits, forestry transportation, packing, lease and inbound transportation among others. Our selling and administrative expenses include overhead, transportation, outsourcing, personnel benefits, consulting, amortization, depreciation, marketing, warehousing, customs, communication expenses, lease, personnel transportation and delivery expenses among others.”

In addition, in our future filings we shall disclose total shipping and handling costs in the financial statement footnotes as follows:

“As of December 31, 2006, 2005 and 2004, shipping and handling costs amounted to ThUS$22,690, ThUS$24,287 and ThUS$19,964 respectively.”

We advise the Staff that with the exception of shipping, handling and warehousing costs, the costs of our distribution network are included in the cost of sales. Therefore, in future filings we will include in the MD&A section a statement that our gross margins may not be comparable to those of other entities, since we include a portion of the costs related to our distribution network in selling and administrative expenses.

Note 23 - Differences Between Chilean and United States General Accepted Accounting Principles.

General

For all income statement periods presented, please revise to include a statement of cash flows prepared in accordance with SFAS 95 or IAS 7. Alternatively, you could furnish, in a note to your financial statements, a quantified description of the material differences between cash flows reported in your primary financial statements and the cash flows that would be reported in a US GAAP statement of cash flows. Refer to Item 17(c)(2)(iii) of Form 20-F and Instruction 4 to Item 17.

In response to the Staff’s comment, we have reviewed Item 17 (c)(2)(iii) to Form 20-F and concluded that there are no material differences between cash flows reported in our Chilean GAAP financial statements and cash flows that would be reported in a statement of cash flows prepared in accordance with accounting principles generally accepted in the United States. We shall include this statement in the note of “differences between Chilean and United States Generally Accepted Accounting Principles” as follows:

“There are no material differences between cash flows reported in our Chilean GAAP financial statements and cash flows that would be reported in a statement of cash flows prepared in accordance with accounting principles generally accepted in the United States.”

f) Segment Information on page F

6.	Please revise your segment disclosures to present intercompany items separate from other items. Please also revise to quantify the extent to which each of your segments is doing business with each other segment for each period presented.

In response to the Staff’s comments, we will revise our segment disclosures and we will present intercompany items separate from other items as well as inter segment transactions, as follows:

December 31, 2006	Chile		Brasil		Venezuela		Mexico		USA		Argentina		Other		Intercompany eliminations			Total
	ThCh$		ThCh$		ThCh$		ThCh$		ThCh$		ThCh$		ThCh$		ThCh$			ThCh$
Sales to unaffiliated customers		168,371		135,557		99,262		118,325		211,833		96,938		56,221		-			886,507
Inter-segment sales		142,362		50,728		27,859		185		-		25,243		-		(246,378	)		-
Total sales		310,733		186,285		127,121		118,510		211,833		122,181		56,221		(246,378	)		886,507

Operating income		17,146		23,432		6,261		6,772		3,567		23,423		2,978		-			83,579
Capital expenditures		72,683		31,423		14,077		871		68		9,022		635		-			128,779
Depreciation		14,484		12,851		12,545		1,372		585		8,326		140		-			50,303

December 31, 2006	Chile		Brasil		Venezuela		Mexico		USA		Argentina		Other		Intercompany eliminations			Total
	ThCh$		ThCh$		ThCh$		ThCh$		ThCh$		ThCh$		ThCh$		ThCh$			ThCh$
Sales to unaffiliated customers		122,427		102,423		75,806		113,379		191,520		85,678		52,760		-			743,993
Inter-segment sales		123,165		54,017		23,742		141		-		19,212		-		(220,277	)		-
Total sales		245,592		156,440		99,548		113,520		191,520		104,890		52,760		(220,277	)		743,993

Operating income		18,233		21,092		3,453		683		1,996		19,517		14,495		-			79,469
Capital expenditures		35,233		18,620		8,239		1,629		541		8,785		119		-			73,166
Depreciation		15,935		12,232		11,983		1,454		728		8,331		28		-			50,691

7.	As a related matter, please revise your segment MD&A disclosures to discuss the business reasons for the changes between periods in the “other” segment.

In response to the Staff’s comment, we shall revise in future filings our MD&A disclosure to discuss the business reasons for the changes between periods in the “Other” segment.

* * * *

In connection with the above-referenced filing, the Company acknowledges that:

The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We hope that the foregoing is responsive to your comments. If you have any questions with respect to this letter, please feel free to contact the undersigned at (562) 350-6004.

Thank you in advance for your cooperation in these matters.


		Very truly yours,


		Engenio Arteaga Infante
		Chief Financial Officer
		Masisa S.A.

Enclosures

cc:	Rufus Decker, Securities and Exchange Commission

Patricio Reyes, Esq., Masisa S.A

Richard M. Kosnik, Esq., Jones Day