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    Broadwater Park

    Denham

    Buckinghamshire UB9 5HR

    United Kingdom

    July 21, 2022

    Switchboard +44 (0) 1895 512 000

    www.ihg.com

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mark Rakip and Kristina Marrone

    Re:

    InterContinental Hotels Group PLC

    Form 20-F for Fiscal Year Ended December 31, 2021

    Filed March 3, 2022

    File No. 001-10409

Dear Mr Rakip,

Thank you for your letter dated July 11, 2022 setting forth comments
of the staff (the “Staff”) of the Securities and Exchange Commission regarding the Annual Report on Form 20-F for the
fiscal year ended December 31, 2021 (the “2021 Form 20-F”) of InterContinental Hotels Group PLC (“IHG”).

To facilitate your consideration of IHG’s response, we have included
below the comment and have provided IHG’s response immediately following.

Form 20-F for fiscal year ended December 31, 2021

Group Cash Flow Summary, page 58, and adjusted EBITDA reconciliation,
page 223

1. We note the non-IFRS financial measures of Adjusted EBITDA and
Adjusted Free Cash Flow as part of your group cash flow summary appear to be intended as liquidity measures, yet appear to comingle performance
and liquidity measures given the reconciliation commences with Operating profit from reportable segments. If your intention is to present
liquidity-based measures, please reconcile such measures from the most directly comparable measure of Cash flow from operations calculated
in accordance with IFRS as issued by the IASB.

3. We note your Adjusted EBITDA reconciliation begins with Operating
profit/(loss). Please revise to reconcile this non-IFRS financial measure to the most directly comparable measure calculated in accordance
with IFRS as issued by the IASB, which would be Profit/(loss) for the year from continuing operations. Refer to Question 103.02 of the
Division's Non-GAAP Financial Measures Compliance & Disclosure Interpretations.

Response:

Although Adjusted EBITDA can be used to compare the performance of different
companies, this measure is primarily used by IHG in the context of liquidity and leverage. The Group’s primary measure for monitoring
capital management is net debt divided by Adjusted EBITDA, with management seeking to maintain a ratio of 2.5-3.0x (as disclosed on pages
12, 54, 76 and 192 of the 2021 Form 20-F).

As set out in our definitions of key performance measures (including
non-GAAPs) on page 76 of the 2021 Form 20-F, Adjusted EBITDA is also used by the Group’s lending banks and credit rating agencies
as an approximation of operational cash flow generation. The Group is furthermore subject to bank covenants which use a leverage ratio
of EBITDA: net debt (note that this ratio is now virtually identical to Adjusted EBITDA, since it is no longer calculated on a frozen
GAAP basis since refinancing in 2022).

Since Adjusted EBITDA is intended primarily to be used as a liquidity
measure, going forward we will amend the reconciliation of Adjusted EBITDA on page 223 to use ‘cash flow from operations’
as the most directly comparable GAAP measure. We will also refine the definition of Adjusted EBITDA on page 76 accordingly. The proposed
amended definition and reconciliation is included in Appendix 1 to this response letter.

Noting also your comments on the comingling of performance and liquidity
measures, going forward we will remove the measures ‘operating profit from reportable segments’ and ‘depreciation and
amortisation’ from the summary cash flow on page 58. The revised cash flow summary, re-presented for 2021, is included in Appendix
2 to this response letter. We believe it is helpful to users and lenders to provide the linkage between Adjusted EBITDA and net debt in
the cash flow summary. We will continue to present the nearest GAAP measure with greater or equal prominence and to ensure all references
to Adjusted EBITDA and Adjusted free cash flow are clearly cross referenced to the appropriate non-GAAP reconciliations.

Performance, page 62

2. It appears that your presentation of Total Gross Revenue in IHG's
System is akin to a billings metric for total sales generated across the IHG Group portfolio, given that you disclose it is not revenue
wholly attributable to IHG as it is mainly derived from hotels owned by third parties. Please tell us how you considered Item 10(e) of
Regulation S-K, as well as the Commission's Guidance on Management’s Discussion and Analysis of Financial Condition and Results
of Operations within Release No. 33-10751 in regards to your Total gross revenue amount, and consider renaming your measure to a billings
or similarly titled amount so as not to be confused with revenue you record. Further, we note that elsewhere in the filing you refer to
"a reconciliation of total gross revenue to owned, leased and managed revenue as recorded in the Group Financial Statements [that]
can be found on page 60." The table on page 60 is not a reconciliation, but rather a disaggregation of the components of Total gross
revenue. Please advise.

Response:

Total Gross Revenue is defined on page 73, with the definition beginning
“Total Gross Revenue is revenue not wholly attributable to IHG”. This statement is repeated for further emphasis in the KPI
description on page 51. We do not consider Total Gross Revenue to be a non-GAAP measure in accordance with Regulation G (17 CFR 244.101),
but a KPI, although accept that the referencing on page 60 which refers to non-GAAP measures could be confusing.

To reduce any possibility of confusion, going forward we will amend
the references on page 60 to “Total Gross Revenue is not wholly attributable to IHG. Definitions for this KPI can be found on page
[73].” We will also amend the description of the table on page 60 to a ‘disaggregation’ of Total Gross Revenue, comprising
revenue attributable to IHG ($0.2bn in 2021) and revenue not recognised in IHG’s income statement ($19.2bn).

The name ‘Total Gross Revenue’ has been used for many years
and we do not believe it causes any confusion. One of the primary reasons for its use is that the term “Gross revenue” is
used within most of the Group’s franchise and management contracts as the basis for the calculation of IHG fees and is therefore
well understood by owners and other stakeholders. On this basis, we believe that renaming this metric and deviating from contractual definitions
would increase the possibility of confusion. We propose to enhance our definition of Total Gross Revenue to clarify that this definition
provides consistency with the Group’s management and franchise contracts as set out in Appendix 3 to this response letter.

I hope that you find our response helpful in addressing your comments.

Yours sincerely,

/s/ Paul Edgecliffe-Johnson

Paul Edgecliffe-Johnson

Chief Financial Officer & Group Head of Strategy

    CC:
    Giles Hannam, Pricewaterhouse Coopers LLP

    Sarah Kokot, Ernst & Young LLP

Appendix 1 – proposed Adjusted EBITDA definition and reconciliation

One of the key measures used by the Group in monitoring its debt and
capital structure is the net debt: adjusted EBITDA ratio, which is managed with the objective of maintaining an investment grade credit
rating. The Group has a stated aim of maintaining this ratio at 2.5-3.0x. Adjusted EBITDA is defined as cash flow from operations, excluding
cash flows relating to exceptional items, cash flows arising from the System Fund result, other non-cash adjustments to operating profit
or loss, working capital and other adjustments, and contract acquisition costs (key money).

Adjusted EBITDA is useful to investors as an approximation of operational
cash flow generation and is also relevant to the Group’s banking covenants, which use Covenant EBITDA in calculating the leverage
ratio. Details of covenant levels and performance against these is provided in note 24 to the Group Financial Statements.

    Non-GAAP reconciliation of Adjusted EBITDA

    (page 223)

    12 months
    12 months

    2021
    2020

    $m
    $m

    Cash flow from operations 1
    848
    308

    Adjusted for:

    Cash flows relating to exceptional items

    12
    87

    Other non-cash adjustments to operating profit/loss
    (71)
    (100)

    System Fund result
    11
    102

    System Fund depreciation and amortisation
    (94)
    (62)

    Other non-cash adjustments to System Fund result
    (6)
    (97)

    Working capital and other adjustments
    (110)
    27

    Capital expenditure: contract acquisition costs (key money)
    42
    64

    Adjusted EBITDA
    632
    329

1 See page 148 Group statement of cash flows

Appendix 2 – proposed revisions to cash flow summary

    Group cash flow summary (page 58)

    12 months
    12 months

    2021
    2020

    GAAP cash flow summary
    $m
    $m

    Net cash from operating activities
    636
    137

    Net cash from investing activities
    (12)
    (61)

    Net cash from financing activities
    (860)
    1,354

    Net movement in cash and cash equivalents
    (236)
    1,430

    12 months
    12 months

    2021
    2020

    $m
    $m

    Adjusted EBITDA[1]
    632
    329

    Working capital and other adjustments
    110
    (27)

    Other non-cash adjustments to operating profit/loss
    71
    100

    System Fund result
    (11)
    (102)

    Non-cash adjustments to System Fund result
    100
    159

    Capital expenditure: contract acquisition costs (key money)
    (42)
    (64)

    Cash flows relating to exceptional items
    (12)
    (87)

    Cash flow from operations
    848
    308

    Net interest paid
    (126)
    (130)

    Tax paid
    (86)
    (41)

    Net cash from operating activities
    636
    137

    Capital expenditure: maintenance
    (33)
    (43)

    Principal element of lease payments
    (32)
    (65)

    Purchase of shares
    0
    0

    Adjusted free cash flow[1]
    571
    29

    Capital expenditure: Gross recyclable investments
    (5)
    (6)

    Capital expenditure: Gross System Fund investments
    (19)
    (35)

    Deferred consideration paid
    (13)
    0

    Disposals and repayments, including other financial assets
    58
    18

    Distributions from associates and joint ventures
    0
    5

    Dividends and shareholder returns
    0
    3

    Other items / proceeds from currency swaps
    0
    0

    Net cash flow before other net debt movements
    592
    14

    Add back principal element of lease repayments within free cash flow
    32
    65

    Exchange and other non-cash movements
    24
    57

    Decrease in net debt
    648
    136

    Net debt at beginning of the year
    (2,529)
    (2,665)

    Net debt at end of the year1
    (1,881)
    (2,529)

1 Definitions
for Non-GAAP measures can be found on pages 73 to 77. Reconciliations of these measures to the most directly comparable line items within
the Group Financial Statements can be found on pages 218 to 223.

Appendix 3 – proposed definition of Total Gross Revenue

Total gross revenue is revenue not wholly attributable to IHG, however,
management believes this measure is meaningful to investors and other stakeholders as it provides a measure of System performance, giving
an indication of the strength of IHG’s brands and the combined impact of IHG’s growth strategy and RevPAR performance.

Total gross revenue refers to revenue which IHG has a role in driving
and from which IHG derives an income stream. IHG’s business model is described on pages 10 to 13. Total gross revenue comprises:

• total rooms revenue from franchised hotels;

• total hotel revenue from managed hotels including food
and beverage, meetings and other revenues and reflects the value IHG drives to managed hotel owners by optimising the performance of their
hotels; and

• total hotel revenue from owned, leased and managed
lease hotels.

Other than total hotel revenue from owned, leased and managed lease
hotels, total gross revenue is not revenue attributable to IHG as managed and franchised hotels are owned by third parties.

Total Gross Revenue is used to describe this measure as it aligns with
terms used in the Group’s management and franchise agreements and therefore is well understood by owners and other stakeholders.