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CORRESP
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CORRESP

 April 14, 2020

Via E-mail

Michael Coco

 Division of Corporation Finance

Office of International Corporate Finance

 U.S.
Securities & Exchange Commission

 100 F Street, NE

Washington, DC

Re:
 The Republic of Argentina

 Registration Statement under Schedule B

 Filed March 16, 2020

 File No. 333-237192

 Form 18-K for Fiscal Year Ended December 31, 2018, as amended

 Filed October 2, 2019 as amended March 9, 2020

 File No. 033-70734

Dear Mr. Coco:

 This letter responds to comments of the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the letter dated April 10, 2020, regarding the above-referenced Registration Statement under Schedule B (the
“Registration Statement”) and Annual Report on Form 18-K (as amended, the “Annual Report”) of the Republic of Argentina (the “Republic” or
“Argentina”).

 For your convenience, we have reproduced below, in bold, the Staff’s comments, and provided responses immediately
below the comments. Capitalized terms used but not defined shall have the meaning set forth in the Registration Statement or the Annual Report, as applicable.

 We make page references in the responses set forth below as indicated to the pages in the Amendment
No. 2 to the Republic’s Annual Report (the “Amendment to the Annual Report”) or Pre-Effective Amendment No. 1 to the Registration Statement (the “Pre-Effective Amendment”), as filed via EDGAR on the date hereof.

 General

1.
 Please disclose any material impact that COVID 19 or the Republic’s response to it has had or may have
on Argentina’s economic, political, health or other conditions in both the near and long term that would be important in making an investment decision in the debt securities including its impact on the Republic’s plan to restructure its
debt. To the extent possible, please provide specific, tailored and thorough disclosure.

 The Republic has included
a section titled “The Argentine Economy—Measures Designed to Address the COVID-19 Outbreak” in the Amendment to the Annual Report (pages D-2 to D-3).

2.
 We note the table on page D-159 to Exhibit D to the Form 18-K that describes non-performing debt and the description on pages 13 and 25 of the registration statement that describes an event of default under the 2005 Indenture and
the 2016 Indenture, respectively. As applicable, please update the table to the extent that the amount of non-performing debt has increased and explain why.

The Republic has updated the disclosure in the “Public Sector Debt—Performing and
Non-Performing Debt” section of the Amendment to the Annual Report (page D-14) to indicate the current amounts of performing debt,
non-performing debt and Untendered Debt (as defined in the Annual Report). The Republic notes to the Staff that non-performing debt refers to public indebtedness of
Argentina that was formally subject to the moratorium declared by the Government in December 2001, other than “Untendered Debt.” Argentina’s non-performing debt encompasses all public debt on
which Argentina is in default as of any given date (other than Untendered Debt), including past due principal and interest payments calculated at contractual rates. Untendered Debt refers to public indebtedness on which Argentina defaulted in
December 2001, and that was not subsequently tendered by the holders into exchange offers conducted in 2005 and 2010 and that has not been settled under the settlement procedures adopted by Argentina in February 2016. The amount of non-performing debt and Untendered Debt (relating to debt issued prior to December 2001) has decreased over time. As of the date of the annual report, Argentina has remained current on all bonds issued since 2005.

3.
 Please revise to include a comprehensive overview of Argentina’s debt restructuring plan.

 As of today, Argentina continues to develop its proposal to adjust its debt burden to make it sustainable for the
long term, but it is unable to provide a comprehensive overview in the Pre-Effective Amendment filed today. The Republic expects to launch in the coming days a consent solicitation that will be addressed to
holders of its foreign-currency-denominated debt securities governed by foreign law (the “Invitation”). It is expected that the Invitation will be open for a period of at least 10 days. The Invitation will be made by means of a
Prospectus Supplement to be filed pursuant to Rule 424(b), which may be amended or supplemented (as so amended or supplemented, the “April 2020 Prospectus Supplement”), and the April 2020 Prospectus Supplement will include
disclosure describing Argentina’s overall plan to make its debt burden sustainable for the long term.

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 Registration Statement under Schedule B

4.
 We note your disclosure on the cover page of the prospectus that the Republic may offer debt securities in
exchange for other debt securities. To the extent that material terms of an exchange are known, please revise the prospectus to include disclosure of them. For example, consider disclosure relating to, but not limited to, the following:

•

 How consents and tenders can be withdrawn,

•

 How consents will be delivered to the issuer,

•

 Causes of termination and how the notice of an extension or termination would be communicated,

•

 The effects on the transaction and on bondholders if minimum consent thresholds are not met,

•

 Highlighting the material differences between the 2005 and the 2016 indentures, and

•

 An explanation of any waterfall provisions.

We may have further comments.

In the Pre-Effective Amendment, the Republic has amended the Registration Statement to clarify that its
debt securities may be offered in exchange for outstanding debt securities, which may include an offer by means of modification of outstanding debt securities pursuant to the collective action clause applicable to such outstanding debt securities.

 As mentioned above, the Republic expects to launch the Invitation in the coming days, which is one such consent solicitation. It will
be addressed to holders of certain of its debt securities, and will be offered pursuant to the April 2020 Prospectus Supplement. The Republic may also use the Registration Statement in the future for other offerings, including offerings
involving future modifications.

 The material terms of transactions that may be offered under the Registration Statement, are not known at
this time and will be disclosed in prospectus supplements. With respect to the Invitation, the April 2020 Prospectus Supplement will include disclosure relating to (i) how consents and tenders can be withdrawn, (ii) how consents will be
delivered to the Republic, and (iii) the effects on the transaction and on bondholders if minimum consent thresholds are not met. In anticipation of such filing, we include under Annex A(4) to this letter draft language that Argentina intends
to include in the April 2020 Prospectus Supplement, which is responsive to the bullet points above. This language remains subject to change as the terms of the Invitation are finalized.

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 2005 Indenture and 2016 Indenture

The Republic has included a section titled “Description of the Securities—Certain Differences Between the 2005 Indenture and the 2016
Indenture” in the Pre-Effective Amendment (page 7) highlighting material differences between the 2005 and the 2016 indentures.

Waterfall provisions

 The
operation of any waterfall provisions for an offering under the Registration Statement will be described in the related Prospectus Supplement. With respect to the waterfall provisions expected to apply to the Invitation, this information will be
provided in full in the April 2020 Prospectus Supplement. We expect it to operate as described below (although details continue to be defined). Eligible bonds issued under the 2016 indenture will be grouped by original maturity into four groups
(2020/2023, 2026/2036, 2046/2048 and 2117), the first three of which will in turn be subdivided by currency (US$, and Euros grouped with CHF). Subject to finalizing details, (a) holders of US$-denominated eligible bonds will be asked to consent
to substitute their bonds for any of four new bonds, with maturities ranging from 2030 to 2048 and interest rates stepping up to 1.75% in the case of the new bonds with the shortest maturity and to 4.875% in the case of the new bonds with the
longest maturity, and (b) holders of Euro or CHF-denominated eligible bonds will be asked to consent to substitute their bonds for any of three new bonds with maturities ranging from 2030 to 2047 and
interest rates stepping up to 1.5% in the case of the new bonds with the shortest maturity to 4.25% in the case of the new bonds with the longest maturity. In the case of the US$-denominated new bonds, three new bonds will be issued up to a maximum
aggregate principal amount for each series (the “bond caps”), while the new bond with the longest maturity will not be subject to a cap. In the case of the Euro-denominated new bonds, two new bonds will be issued up to a bond cap, while
the new bond with the longest maturity will not be subject to a cap.

 When giving their consent, holders of eligible bonds will be asked
to indicate for which of the new bond options they wish their eligible bonds to be substituted. Holders consenting to the proposed modifications with respect to eligible bonds falling within the first group will be entitled to elect among all
available options, and their elections will be respected. Holders consenting to the proposed modifications with respect to eligible bond falling within the second group will be entitled to elect among all available options, and their elections will
be respected to the extent that the elections made by them for any new bonds do not exceed the applicable bond cap (after giving effect to the election made by the holders in the first group). In the event that elections made by the second group
cause the bond cap of any new bond to be exceeded, the eligible bonds of the second group for which consents to substitute for that new bond were given will be prorated and any “excess” eligible bonds will be deemed to have selected, of
the other new bond options, the one with the shorter maturity, until that category is exhausted. Any further excess will be deemed to have elected the new bond with the next shortest maturity. The same process will be repeated with respect to
eligible bonds for which consents were obtained falling within the third group and then the fourth group. In the event that the proposed modifications take effect with respect to any series of eligible bonds, any holders of such bonds that did not
express their consents will be deemed to have elected the new bonds with the longest maturity (denominated in US$ or Euros, as applicable). In the event that the proposed modifications do not take effect with respect to any series of eligible bonds,
the non-consenting holders will retain their eligible bonds.

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5.
 Please disclose whether the exchange offers could be for other debt securities that were issued in private
offerings, and if so, please disclose whether the terms of the public debt securities will be the same as the debt securities sold in private offerings.

The Republic has expanded the disclosure under the section “Plan of Distribution” in pages 45 to 46 of the Registration Statement to
indicate that in general terms securities issued under the Registration Statement may be offered in exchange for other debt securities that were issued in private offerings, which may have different terms than those offered under the Registration
Statement, including with respect to transfer restrictions.

 If an exchange offer under the Registration Statement is for other debt
securities that were issued in one or more unregistered offerings, the applicable prospectus supplement will say so and will disclose whether the terms of the new securities will be the same as the terms of the debt securities sold in unregistered
offerings.

 In the case of the Invitation, disclosure on this topic will be included in the April 2020 Prospectus Supplement. The Republic
expects that the target securities will include holders of all outstanding series issued under the 2005 Indenture and 2016 Indenture. In the case of the outstanding series issued under the 2005 Indenture, none of those securities were issued in the
United States in private offerings. In the case of the Eligible Bonds issued under the 2016 Indenture, the following series of securities were originally issued in the United States in private offerings without registration under the Securities Act:

(i)
 U.S. dollar-denominated 6.875 per cent. International Bonds due 2021 (ISIN USP04808AA23);

(ii)
 U.S. dollar-denominated 5.625 per cent. International Bonds due 2022 (ISIN USP04808AL87);

(iii)
 U.S. dollar-denominated 7.500 per cent. International Bonds due 2026 (ISINs USP04808AC88 and
US040114GS35);

(iv)
 U.S. dollar-denominated 6.875 per cent. International Bonds due 2027 (ISIN USP04808AM60);

(v)
 U.S. dollar-denominated 6.625 per cent. International Bonds due 2028 (USP04808AJ32);

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(vi)
 U.S. dollar-denominated 7.625 per cent. International Bonds due 2046 (ISINs USP04808AE45 and
US040114GU80); and

(vii)
 U.S. dollar-denominated 7.125 per cent. International Bonds due 2117 (ISINs USP04808AN44 and US040114HM55)
(collectively, the “Unregistered Eligible Bonds”).

 On April 18, 2017 and June 26, 2018,
Argentina completed offers to exchange the Unregistered Eligible Bonds for registered bonds with the same terms and conditions as each of the Unregistered Eligible Bonds pursuant to prospectuses filed pursuant to Rule 424(b) dated March 14,
 20171 and May 18, 2018,2
respectively. Since less than all of the Unregistered Eligible Bonds were tendered for exchange for registered bonds, certain residual amounts of Unregistered Eligible Bonds remain outstanding. The Unregistered Eligible Bonds will be allowed to
participate in the Invitation on the same terms and subject to the same conditions as the other Eligible Bonds. The Unregistered Eligible Bonds were issued under the 2016 Indenture and have the same common terms and conditions as those contemplated
for the securities to be offered pursuant to the Invitation.

6.
 Please update the prospectus to include any material negotiations that the Republic of Argentina has had
recently with bondholders to restructure and/or exchange debt securities.

 As mentioned, Argentina continues to
develop its proposal to adjust its debt burden to make it sustainable for the long term. As is customary, discussions with certain groups of investors that approached Argentina are on-going as of the date of
this letter. The April 2020 Prospectus Supplement will include disclosure describing any material negotiations that Argentina had prior to the launch of its transactions recently with significant groups of bondholders relating to Argentina’s
plans to restructure and/or exchange debt securities.

7.
 Please include a risk factor section in the prospectus or advise us why such revision is not necessary.

 Consistent with its prior filings and a practice that is not uncommon among sovereign issuers, Argentina has not
included a risk factor section in its registration statement. As it has done in prior SEC-registered offerings, Argentina intends to include a risk factor section in each prospectus supplement used to offer
securities under the registration statement. In particular, Argentina will include a risk factor section in the April 2020 Prospectus Supplement, addressing various types of risks involved in the transaction. The risks specifically related to the
transaction will be fully identified and drafted once the details are finalized. In anticipation of such filing, we include under Annex A(7) to this letter draft language of the risk factor captions that Argentina intends to include in the
Prosp