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Paul Edgecliffe-Johnson

Group Chief Financial Officer

InterContinental Hotels Group

Broadwater Park

Denham

Buckinghamshire

UB9 5HR

United Kingdom

    Mr Wilson
        K. Lee

        Division
        of Corporation Finance

        Ms Jennifer
        Monick

        Assistant
        Chief Accountant

        Office
        of Real Estate and Commodities

        Division
        of Corporation Finance

        United
        States Securities and Exchange Commission

        Washington
        DC 20549

        U.S.A.

    Direct Tel: +44 (0)1895 512211

pej@ihg.com

15 September
2016

 Re: InterContinental Hotels
Group PLC

Form 20-F
for Fiscal Year Ended December 31, 2015

Filed on
March 3, 2016

File No.
001-10409

Dear Mr Wilson and Ms Monick,

We refer to the letter dated August
10, 2016 from Wilson K. Lee and Jennifer Monick of the Division of Corporation Finance, United States Securities and Exchange
Commission (the “Staff”), to Paul Edgecliffe-Johnson (the “Letter”) relating to the Annual Report on Form
20-F for the fiscal year ended December 31, 2015 (the “Form 20-F”), filed by InterContinental Hotels Group PLC (“IHG”,
the “Company” or, together with its subsidiaries, the “Group”). We are following up with this letter,
which contains our responses to the Staff’s comments contained in the Letter. For ease of reference, the Staff’s comments
are set forth in their entirety along with our responses. References to page numbers in the below response are to the page numbers
in the Form 20-F.

General

 1. We
note your disclosure on pages 28 and 29 that you measure your performance through a set of carefully selected key performance
indicators, including global RevPAR growth. Please tell us whether management considers RevPAR, average daily rate and occupancy
of your franchised properties, your managed properties and your owned and leased properties to be key performance metrics. If
so, please revise future Exchange Act periodic filings to include these performance metrics or advise.

Response:

RevPAR is one of the
key performance metrics used by management to track hotel performance as it is a product of the two key drivers of hotel revenues:
average daily rate (ADR) and occupancy. RevPAR, ADR and occupancy can all be calculated at both an individual hotel level and
on an aggregated basis e.g. by brand (InterContinental, Kimpton, Crowne Plaza and so forth), by segment (Americas, Europe, AMEA
and Greater China) and by business model (Franchised, Managed and Owned and leased). In addition to Global RevPAR, which comprises
all hotels in the IHG System, IHG makes publically available RevPAR, ADR and occupancy statistics on all three of these bases
so as to provide a deeper understanding of our business performance and aid a comparison of our results to our competitors.

The key performance
indicators disclosed on pages 28 and 29 are those that are correlated to measuring our success in achieving our strategy, being
the Winning Model and Targeted Portfolio underpinned by Disciplined Execution and doing business responsibly. This strategy is
set out in detail on page 14 where it can be seen that Global RevPAR growth is the RevPAR performance metric that is used to measure
success against the strategic objectives. Consistent with this, it is also confirmed that Global RevPAR growth is the only RevPAR
measure that has an impact on the remuneration plans of the executive members of the Board.

In terms of the metrics
mentioned in the Staff’s comment - RevPAR, ADR and occupancy at the franchised, managed and owned and leased level –
we use these to track business performance as noted above but do not consider them to be key performance indicators for the Group
as a whole.

Non-GAAP Calculations, page 155

 2. In
                                         future filings please include a statement disclosing the reasons why you believe your
                                         presentation of the non-GAAP financial measures provide useful information to investors.
                                         Please provide us an example of your proposed disclosure. Please refer to Item 10(e)
                                         of Regulation S-K.

Response:

In future filings
we propose to include a new section “Key performance measures used by management” which will be placed at the start
of the Performance review. In the context of our 2015 Form 20-F, this would sit at the top of page 32. See Appendix A for our
proposed wording which includes a discussion as to why the Group’s non-GAAP financial measures provide useful information
to investors.

    2

 3. We
                                         note your narrative reconciliations of your non-GAAP measures for the Group. We note
                                         you disclose these measures on a segment basis within your performance discussion. In
                                         future filings, please also include a schedule to allow the reader to reconcile the non-GAAP
                                         segment measures to your non-GAAP group measures. Please provide us an example of your
                                         proposed disclosure. Please refer to Item 10(e) of regulation S-K.

Response:

In future filings
we propose to include the reconciliation schedule in Appendix B to allow the reader to reconcile the non-GAAP segment measures
to the non-GAAP Group measures. The reconciliation schedule will form a new page that will be placed at the front of the Additional
Information section of the Annual Report. In the context of our 2015 Form 20-F, this would be page 152.

 4. In
                                         future filings, when you are presenting a measure on a constant currency basis, your
                                         reconciliation should present the historical amounts and the amounts in a constant currency.
                                         Please provide us an example of your proposed disclosure. Please refer to Question 104.06
                                         of our Non-GAAP Financial Measures Compliance & Disclosure Interpretations.

Response:

In future filings we
propose to present the actual and constant currency amounts as set out in Appendix B.

In respect of ‘Total gross
revenue’ (see Appendix A), we also propose to make the following additional disclosure under the ‘Global total gross
revenue’ table (see page 33 of our 2015 Form 20-F), thereby providing a reconciliation of Total gross revenue to the Owned
and leased revenue that is included in the Group Financial Statements.

    2015

         $bn

    2014

         $bn

    %

         change

    Franchised
    14.1
    13.4
    5.2

    Managed
    9.6
    9.0
    6.7

    Owned
    and leased*
    0.3
    0.4
    (25.0)

    Total
    24.0
    22.8
    5.3

* see Note [2] of the Group Financial
Statements on page [x]

These new disclosures –
Appendix A, Appendix B and the Total gross revenue reconciliation - will replace our current ‘Non-GAAP calculations’
disclosure.

    3

In connection with our response, we acknowledge that:

 • the Company is responsible
for the adequacy and accuracy of the disclosure in the filings;

 • staff comments or change
to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings;
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 trust that our response to
your comments is satisfactory. If you have any questions or comments in connection with any of the foregoing, please call me at
+44 1895 512211 or Michael Glover, Senior Vice President and Group Financial Controller, at +44 1895 512291. Facsimile transmissions
may be sent to either of us at +44 8701 974277.

Yours sincerely

/s/ Paul Edgecliffe-Johnson

Paul Edgecliffe-Johnson

Chief Financial Officer

InterContinental Hotels Group
PLC

CC: Sarah Kokot, Ernst &
Young LLP

    4

Appendix A

Key performance measures used
by management

In addition to the performance
measures that are directly observable in the Group Financial Statements, the performance review (and Group highlights on page
[x]) include the following key performance measures. The performance review should be read in conjunction with the Non-GAAP Reconciliations
on page [x].

Revenue per Available
Room (RevPAR)

RevPAR is the primary metric used
by IHG’s management to track hotel performance across regions and brands. RevPAR is also a commonly used performance measure
in the hotel industry.

RevPAR comprises IHG System rooms
revenue divided by the number of room nights available and can be mathematically derived from occupancy rate multiplied by average
daily rate. Occupancy rate is rooms occupied by hotel guests expressed as a percentage of rooms that are available. Average daily
rate is rooms revenue divided by the number of room nights sold.

References to RevPAR, occupancy
and average daily rate are presented on a comparable basis comprising groupings of hotels that have traded in all months in both
the current and prior year. The principal exclusions in deriving this measure are new hotels, hotels closed for major refurbishment
and hotels sold in either of the two years.

RevPAR and average daily rate
are quoted at a constant US dollar conversion rate, using prior-year exchange rates, in order to allow a better understanding
of the comparable year-on-year trading performance excluding distortions created by fluctuations in exchange rates.

Total gross revenue*

An important measure of IHG System
performance is the growth in total gross revenue which provides a measure of the overall strength of the Group’s brands.

Total gross revenue comprises
total rooms revenue from franchised hotels and total hotel revenue from managed, owned and leased hotels. Other than owned and
leased hotels, total gross revenue is not revenue attributable to IHG as it is derived mainly from hotels owned by third parties.

A reconciliation of total gross
revenue to the owned and leased revenue included in the Group Financial Statements is set out on page [x].

Underlying revenue
and underlying operating profit growth*

Fee revenue and fee
margin growth*

Underlying revenue and underlying
operating profit both exclude the impact of owned asset disposals, managed leases, significant liquidated damages and current
year acquisitions, all translated at constant currency using prior year exchange rates. Underlying operating profit growth also
excludes the impact of exceptional items (see below). The presentation of these additional performance measures allows a better
understanding of comparable year-on-year trading and thereby allows an assessment of the underlying trends in the Group’s
financial performance. These measures also provide consistency with the Group’s internal management reporting.

Fee revenue and fee margin further
exclude the revenue and operating profit of the Group’s remaining owned and leased properties, thereby providing metrics
which measure the underlying performance of the Group’s core fee-based business model. Fee margin is the underlying operating
profit of the fee business expressed as a percentage of the underlying fee revenue, as further defined in the glossary on page
[x].

The performance review should
be read in conjunction with the Non-GAAP Reconciliations on page [x], which reconcile these alternative performance measures to
the nearest comparable GAAP measures and also show the amounts on both an actual and constant currency basis.

Total operating profit
before exceptional items and tax*

Adjusted earnings
per ordinary share*

Total operating profit before
exceptional items and tax enables a better understanding of the ongoing operational performance of the Group. (For example, total
operating profit including exceptional items can be significantly skewed by the profit on disposal of owned assets, as was the
case in 2015 with the disposal of InterContinental Hong Kong.) In addition, taxes can be influenced by external factors such as
legislative changes, and a before-tax measure of operating profit is therefore considered more reflective of the Group’s
success in executing against its strategy.

Total operating profit both before
and after exceptional items is shown on the face of the Group income statement on page [x], as permitted under IFRS.

Adjusted earnings per ordinary
share excludes exceptional items, and their related tax impacts, and is reconciled to basic earnings per share in note [9] on
page [x] of the Group Financial Statements. Adjusted earnings per share provides an underlying per share measure that is not skewed
by exceptional items.

Exceptional items are identified
by virtue of either their size or nature and are excluded from these measures so as to facilitate comparison with prior periods
and to assess underlying trends in financial performance. Exceptional items can include, but are not restricted to, gains and
losses on the disposal of assets, impairment charges and reversals, and restructuring costs. An analysis of exceptional items
for the periods covered by the performance review is included in note [5] on page [x] of the Group Financial Statements.

Net debt*

Net debt comprises loans and other
borrowings less cash and cash equivalents, and is reconciled to the amounts included in the Group Financial Statements in note
[24] on page [x].

Net debt is used in the monitoring
of the Group’s liquidity and capital structure, and is a number used to calculate the key ratios attached to the Group’s
bank covenants.

* these are non-GAAP
financial measures which should be viewed as complementary to, and not as a substitute for, the measures prescribed by GAAP

    Non-GAAP Reconciliations
    Appendix B

The following tables:

 • show underlying revenue
and underlying operating profit on both an actual and constant currency basis*

 • reconcile segmental underlying
revenue and underlying operating profit to Group underlying revenue and operating profit

 • show underlying Group fee
revenue and Group fee margin on both an actual and constant currency basis*

 • reconcile Group underlying
revenue and underlying operating profit to the GAAP measures included in the Group financial statements

Highlights for the
year ended 31 December 2015

    At actual
    exchange rates

    At constant
    exchange rates

    2015
    2014
    Change
    Change

    2015
    2014
    Change
    Change

    $m
    $m
    $m
    %

    $m
    $m
    $m
    %

    Underlying Revenue

    Americas
    858
    803
    55
    6.8%

    874
    803
    71
    8.8%

    Europe
    160
    173
    (13)
    -7.5%

    186
    173
    13
    7.5%

    AMEA
    195
    201
    (6)
    -3.0%

    214
    201
    13
    6.5%

    Greater China
    109
    103
    6
    5.8%

    111
    103
    8
    7.8%

    Central
    135
    129
    6
    4.7%

    137
    129
    8
    6.2%

    Underlying Group revenue
    1,457
    1,409
    48
    3.4%

    1,522
    1,409
    113
    8.0%

    Owned and leased revenue included above
    (164)
    (154)
    (10)

    (170)
    (154)
    (16)

    Underlying Group fee revenue (exc Kimpton)
    1,293
    1,255
    38
    3.0%

    1,352
    1,255
    97
    7.7%

    Kimpton
    56
    0
    56

    56
    0
    56

    Underlying Group fee revenue (inc Kimpton)
    1,349
    1,255
    94
    7.5%

    1,408
    1,255
    153
    12.2%

    Underlying Operating profit

    Americas
    579
    538
    41
    7.6%

    591
    538
    53
    9.9%

    Europe
    76
    73
    3
    4.1%

    90
    73
    17
    23.3%

    AMEA

        Greater China

    81
    80
    1
    1.3%

    87
    80
    7
    8.7%

    41
    47
    (6)
    -12.8%

    42
    47
    (5)
    -10.6%

    Central