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August 18, 2023

Ms. Megan Akst (Senior
Staff Accountant)

Ms. Christine Dietz
(Senior Staff Accountant)

U.S. Securities
and Exchange Commission

Washington, D.C.
20549

 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 Ms. Akst and
Ms. Dietz,

This letter is submitted
in response to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) contained in your letter dated July 14, 2023 (the “Comment Letter”) with
respect to the financial statements and related disclosures of the Form 20-F for the Fiscal Year Ended December 31, 2022 filed by Millicom
International Cellular S.A. (“Millicom” or the “Company”) with the Commission on February 28, 2023.

For
your convenience, we have reproduced the Staff’s comments preceding our responses below. Please do not hesitate to contact Celso
Vianna (Chief Accounting Officer) celso.vianna@millicom.com, Geoffrey Smets (Group Financial Reporting Director) geoffrey.smets@millicom.com or myself with any questions.

Very truly yours,

 /s/
Sheldon Bruha

Sheldon
Bruha

Chief
Financial Officer

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.

Response:

Cost
of Sales (“COS”) includes direct costs of services sold (such as toll charges, own customers roaming costs, transmission
costs, SMS direct costs, Voice Value Added Services (“VAS”) direct costs, Data direct costs, Content direct costs, Business
services direct costs, Other VAS direct costs and Financial services direct costs from the Company’s Mobile Financial Services)),
cost of telephone, equipment and other accessories and bad debt and obsolescence. COS does not include depreciation and amortization
of assets that are required to generate revenue. COS does not include any indirect cost of services necessary to generate revenue.

In
determining what to include in COS, the Company considered the guidance in paragraphs 99, 100, 101 and 105 of IAS 1, which provides two
possible methods to present an analysis of expenses recognized in the consolidated statement of income (i.e., either by nature or by
function). The Company also considers that IAS 1 encourages but does not require the chosen analysis to be shown on the face of the statement
of income, as well as that entities are permitted to disclose the classification on the face on a mixed basis, as long as the required
classification is provided in the notes. Indeed, the IASB itself produces an example of such a statement of income in an illustrative
example to IAS 7 (IAS7.IEA).In light of the applicable guidance, the Company primarily applies the ‘nature of expense’ method
to present an analysis of expenses recognized in the consolidated statement of income for the following reasons:

 o It
                                            allows a better understanding of the components of the Company’s operating income,

 o The
                                            analysis of expenses (like the depreciation and amortization or employee related costs) and
                                            their classification according to their ‘function’ as part of COS and operating
                                            expenses, involve considerable judgmental and it does not compare with the Company’s
                                            peers,

 o This
                                            presentation is not uncommon in the telecommunication industry and therefore allows a better
                                            basis for comparison with other peers (such as AMÉRICA MÓVIL, S.A.B. DE C.V.,
                                            which presents costs and expenses in its consolidated statement of income in a combined manner
                                            -based on their function and nature-) and

 o Historically,
                                            the company has always analyzed its expenses by their nature (see the financial statements
                                            in our Form 20-Fs for the years ended December 31, 2018, December 31, 2019, December 31,2020,
                                            December 31, 2021 and December 31, 2022).

The
Company acknowledges that paragraph 103 of IAS 1, which provides guidance with respect to the analysis method by ‘function of expense’,
requires entities to disclose COS separately from other expenses. The Company notes, however, that there is no clear definition of COS
under IFRS. Per our knowledge, IASB has not proposed a clear definition of COS in its Primary Financial Statement Project (PFS project)
and will likely not do so when finalizing its proposals. As stated in the staff paper A21F from September 2022, the staff has set out
that even though COS is a key line item when operating expenses are presented by function and feedback from respondents indicated that
diversity in practice exists on what it includes, it would be difficult to develop a definition of COS within a reasonable timeframe
and undertaking such work would delay completion of the project. Therefore, IASB tentatively decided not to define COS as part of the
PFS project.

To
achieve a fair presentation, as required in paragraph 15 and BC 56 of IAS 1, the details of the COS are disclosed in note B.2. ‘Expenses’,
i.e. ‘direct costs of services sold’ (which include toll charges, own customers roaming costs, transmission costs, SMS direct
costs, Voice VAS direct costs, Data direct costs, Content direct costs, Business services direct costs, Other VAS direct costs and Financial
services direct costs), ‘cost of telephone, equipment and accessories’ and ‘bad debt and obsolescence costs’.

Management
believes that the current presentation method of an analysis of expenses (i.e., on a mixed basis, which is primarily by ‘nature
of expense’ and COS as a separate line item), and additional disclosures made in note B.2. ‘Expenses’ are in agreement
with IAS 1 and are consistent with the requirements of paragraphs 15 and B56, 99, 100 and 105 of IAS 1 and present fairly the consolidated
statement of income of the Company.

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 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.

Response:

Generally,
the Company’s risks and rates of return for its operations were predominantly affected by operating in different geographical regions.
Until the divestiture of our ultimate operation in Africa (i.e., Tanzania business) in April 2022, the Company had businesses in two
main regions, Latin America and Africa, which constituted two geographical segments, and were reflected as such in our consolidated financial
statements in accordance with paragraph 22 of IFRS 8. As a result of the sale of the Tanzania business in April 2022, the Company no
longer reported an Africa segment in the consolidated financial statements and the historical results of Tanzania operations through
the date of divestiture were reflected under the statement of income caption “Discontinued operations” in the consolidated
financial statements. Since then, the Company operates in a single geographical region, Latin America (‘Latam’).

As
a result, the Company reports a single segment, called ‘Group Segment’, which includes the Latam figures and central corporate
costs. Group segment figures include Honduras joint venture as if it was fully consolidated, as this reflects the way management reviews
and uses internally reported information to make decisions about operating matters, reviews the Company financial performance, allocates
resources, and remunerates management’s performance (bonuses). It also provides increased transparency to investors on those operations.

In
Millicom the Chief Executive Officer (CEO) is responsible for leading the development and execution of the Company’s strategy,
the day-to-day activities and management decisions, both operating and financial. Furthermore, Millicom’s Executive Team members
support the CEO in the day-to-day operation and management of the Company, within their specific areas of expertise.

Chief
Financial Officer (CFO) reports to the CEO and is responsible for finance and financial planning. Reporting financial performance, including
external financial reporting. Budgeting and forecasting, monitoring expenditures and costs. Implementation and enhancement of related
controls. Risk management.

In
Millicom, the responsible people for allocating resources and to assess the performance of the components of the Company are the CEO
and the Executive Team members, therefore the CODM role resides within this group of people (CEO and Executive Team members).

Millicom
CEO and Executive Team is composed as follows (extract from Millicom 2022 Annual Report):

The
CEO and the Executive Team members have regular contact with the COO (Latam business manager) (effectively there is only one reportable
segment), country General Managers and country Chief Financial Officers (local Managers) to assess the Company performance. CODM reviews
monthly financial performance for every country and region. Upon the operating countries submit the monthly reporting to the Company,
the COO (Latam business manager) and local Managers discuss performance through live calls. Monthly finance calls are structured by operating
country and usually the CEO, COO (segment Manager) and local General Managers and CFOs attend the live sessions to discuss monthly performance.
The same approach is followed for the purpose of the yearly budget process.

This
view is consistent with current way of reporting in accordance with paragraphs 5 and 22 of IFRS 8, and it is based on the following:

 Ø Qualitative
                                            aspects: Millicom is an international telecommunications and media group providing digital
                                            lifestyle services in emerging markets, through mobile and fixed telephony, cable, broadband,
                                            Pay-Tv in Latin America. The Chief Operating Decision Maker (CODM) makes resource allocation
                                            decisions based on its strategic global positioning to strength its leadership position in
                                            Latam and with a view of maximizing the financial results of the Company. Millicom’s
                                            business strategy grounded on six interconnected areas (monetize mobile, expand broadband,
                                            drive convergence, accelerate B2B, go digital and customer centricity) is considered within
                                            a Latam reference, even at the expense of one or more of its countries.

The
CODM has access to the underlying detailed financial information on a regional level, including more granular information (Country by
Country and disaggregated revenue by Business Unit). However, the CODM allocates resources to grow the business on a regional basis (Latam).
As noted above, the Company’s risks and rates of return are predominantly affected by operating in one geographical region. Such
regional structure allows the CODM to assess performance as well as determine compensation and benefits packages.

Furthermore,
there is a ‘capital budgeting and approval process’, through which the CODM reviews and allocates CAPEX investments’
portfolio across the Group Segment. On a regular basis, the Global Investment Strategy team holds CAPEX / Capital Allocation Requests
(CAR) committee meetings to review, approve and allocate CAPEX investments across the Group Segment depending on needs. The total amount
of the portfolio is defined as part of the budget process and remains unchanged over the year which means that CAPEX allocation between
countries might be changed during the year and done at the expense of certain individual operations to the benefit of others.

Additionally,
the Company finance team has been transforming into one best-in-class digital partner, focusing on i) the standardization of processes
and controls; ii) the centralization of accounting resources and finance function in a Single Shared Service Center; iii) the digitalization
of every finance tool across the Group Segment. This finance transformation/centralization aligns with the way management assesses performance
and allocates resources across the Group (i.e., on a regional/portfolio basis).

 Ø Quantitative
                                            aspects: Millicom serves customers in nine Latin American markets— Bolivia, Colombia,
                                            Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, Panama and Paraguay, with a focus
                                            on consolidating its regional footprint in Latam. Considering this spectrum of countries
                                            in Latam, most Latam’s countries would not exceed the quantitative thresholds in reference
                                            to revenue, profit and loss, and assets mentione