SecProbe.io

United States securities and exchange commission logo
July 14, 2023
Sheldon Bruha
Chief Financial Officer
Millicom International Cellular S.A.
2, Rue du Fort Bourbon
L-1249 Luxembourg
Grand Duchy of Luxembourg
Re:Millicom International Cellular S.A.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed February 28, 2023
File No. 001-38763
Dear Sheldon Bruha:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 18. Financial Statements
Consolidated statement of income for the years ended December 31, 2022, 2021 and 2020, page
F-5
1.The amount reported as cost of sales (“COS”) appears to be incomplete as it appears to
exclude the depreciation and amortization of assets that are required to generate revenue.
Also, the table on page F-35 indicates that COS includes the direct cost of services sold.
Please tell us whether COS includes any indirect cost of services necessary to generate
revenue.  In this regard, we note that the operating expense line item includes site and
network maintenance costs and employee related costs some of which may relate to COS.
Please support your presentation under IAS 1 and explain how you determined that your
measure of cost of sales is complete.  We refer you to paragraphs 15 and BC 56 of IAS 1.

 FirstName LastNameSheldon  Bruha
 Comapany NameMillicom International Cellular S.A.
 July 14, 2023 Page 2
 FirstName LastName
Sheldon  Bruha
Millicom International Cellular S.A.
July 14, 2023
Page 2
Notes to Consolidated Financial Statements
Note B.3. Segmental Information, page F-36
2.You disclose that you have a “single segment” called the Group Segment.  Please tell us
and revise to disclose the factors used to identify your reportable segments, including the
basis of organization (for example, whether management has chosen to organize the
company around differences in products and services or geographic area).  Refer to
paragraph 22 of IFRS 8.  Tell us how you identified your operating segments based on the
criteria provided in paragraph 5 of IFRS 8 and provide us with a list of these operating
segments.  As part of your response, please tell us whether the countries listed on page 63
are operating segments.  In this regard, we refer you to your earnings release furnished on
April 27, 2023, where you quantify and discuss revenue and EBITDA by country such
that it appears discrete financial information may be available.  To the extent you have
more than one operating segment, please tell us how you considered the aggregation
criteria in paragraph 12 of IFRS 8 and the quantitative thresholds in paragraph 13
of IFRS 8 in determining your reportable segment. Please be detailed in your response.
3.We note that you include your Honduras joint venture as if it was fully consolidated.
Provide your analysis that supports the aggregation of the Honduras joint venture with
your other operating segments.  Refer to paragraph 12 of IFRS 8.  Also, please tell us why
you include the Honduras joint venture on a fully consolidated basis when you only own
66.7% and refer to the authoritative guidance that supports this presentation.
4.We note you present operating profit (loss), EBITDA and EBITDA incl discontinued
operations as the Group's measures of segment profit (loss).  Please tell us how you
considered paragraph 26 of IFRS 8, which indicates that if the chief operating decision
maker uses more than one measure of an operating segment’s profit or loss the reported
measures shall be those that management believes are determined in accordance with the
measurement principles most consistent with those used in measuring the corresponding
amounts in the entity’s financial statements (i.e. operating profit (loss)).  Also,
notwithstanding comment number 2 above, to the extent that a measure is not identified as
the segment measure of profit or loss under IFRS 8 and is presented outside the
consolidated financial statements, for example the disclosures on pages 62 and 67, we
may have additional concerns.
5.We note your presentation of an additional segment measure, operating free cash flow.
Please explain your basis for including this measure and provide the specific guidance you
relied upon. To the extent this is not required by IFRS, please revise to remove this
apparent non-IFRS measure from your financial statement footnotes.  Refer to Item
10(e)(1)(ii)(C) of Regulation S-K.

 FirstName LastNameSheldon  Bruha
 Comapany NameMillicom International Cellular S.A.
 July 14, 2023 Page 3
 FirstName LastName
Sheldon  Bruha
Millicom International Cellular S.A.
July 14, 2023
Page 3
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Savadore Escalon