CORRESP

Farfetch UK Limited changed from pound sterling to the U.S. Dollar on January 1, 2019 because of a change in its underlying transactions, events and conditions whereby the dominant currency of Farfetch UK Limited’s sales, operating receipts, costs and financing activities gradually moved away from pound sterling to U.S. Dollars. The functional currency of Farfetch Limited, the ultimate parent of Farfetch UK Limited, is U.S. Dollars, which has not changed since Farfetch Limited was incorporated, and became the ultimate parent of Farfetch UK Limited, immediately prior to Farfetch Limited’s initial public offering in 2018 (the “IPO”), as described in our registration statement filed in connection with that offering.

IAS 21: The Effects of Changes in Foreign Exchange Rates, paragraphs 9 through 13 define the functional currency as the currency of the primary economic environment in which the entity operates. It lists factors to determine the functional currency being the currency that mainly influences sales prices as well as labor, materials and other costs for goods and services. It also says that the currency in which funds from financing activities and operating receipts are retained are also indictors. Whilst Farfetch UK Limited’s operations and employees are primarily located outside the United States, as indicated by the Staff, the United States is the largest single operating market for Farfetch UK Limited from a consumer location (or demand) perspective. As a result, Farfetch UK Limited predominantly prices items sold, and generates cash (and also retains this cash) in U.S. Dollars, and the U.S. Dollar is the dominant currency for the income, costs and cash flows of Farfetch UK Limited.

Historically, pound sterling cash flows were most significant to the business, however, in January 2019, the most recently available three-year cash flow projections for Farfetch UK Limited indicated that the U.S. Dollar will continue to grow as the business’s most significant currency. We expect this trend to continue for the foreseeable future. This analysis also included the recent mergers and acquisitions we have made. We also note that Farfetch UK Limited’s operating costs are directly and indirectly influenced by U.S. Dollars. A significant proportion of Farfetch UK Limited’s fulfillment and demand generation costs are linked to the U.S. Dollar, whereby the pound sterling equivalent incurred fluctuates as foreign exchange rates change. It should also be noted that Farfetch UK Limited’s finance and funding activities are also denominated in U.S. Dollars, including its funding via Farfetch Limited’s IPO proceeds, which are recorded as intercompany loans. Farfetch UK Limited retains the majority of its cash in U.S. Dollars.

After due consideration of the IAS 21 guidance in paragraphs 9 through 13, we concluded the U.S. Dollar to be the dominant currency of Farfetch UK Limited following our review of Farfetch UK Limited’s historic trading results and cash flows against the guidance. This was also consistent with our three-year cash flow projections finalized in January 2019. From the timing of this review, which coincided with our annual budgetary process, we determined that the change of functional currency occurred on January 1, 2019 when this process was completed.

If you have any questions or require additional information, please do not hesitate to call me at +44 20 7549 5900.

Very truly yours,

/s/ Elliot Jordan

Elliot Jordan

Chief Financial Officer

cc:	(via email)

James Maynard, Farfetch Limited

Ian D. Schuman, Esq., Latham & Watkins LLP