SEC Comment Letter for GAS TRANSPORTER OF THE SOUTH INC (TGS) (CIK 0000931427) (TGS) — Oct 31, 2022
GAS TRANSPORTER OF THE SOUTH INC (TGS) (CIK 0000931427)
Date: Oct. 31, 2022 · CIK: 0000931427 · Accession: 0000000000-22-011847
AI Filing Summary & Sentiment
File numbers found in text: 001-13396
Letter
United States securities and exchange commission logo October 31, 2022 Alejandro M. Basso Chief Financial Officer and Services Vice President Gas Transporter of the South Inc. Don Bosco 3672, 5th Floor C1206 ABF City of Buenos Aires, Argentina Re:Gas Transporter of the South Inc. Form 20-F for Fiscal Year Ended December 31, 2021 Filed April 26, 2022 Form 6-K Filed August 9, 2022 File No. 001-13396 Dear Alejandro M. Basso: 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 Fiscal Year Ended December 31, 2021 Item 5. Operating and Financial Review and Prospects A. Operating Results Year 2021 Compared to Year 2020, page 129 1.Please discuss and analyze material changes to your balance sheet, and discuss material events and uncertainties that may impact your future financial condition. Refer to Part 1, Item 5 of Form 20-F.
FirstName LastNameAlejandro M. Basso Comapany NameGas Transporter of the South Inc. October 31, 2022 Page 2 FirstName LastName Alejandro M. Basso Gas Transporter of the South Inc. October 31, 2022 Page 2 Form 6-K Filed August 9, 2022 Second Quarter Ended June 30, 2022, page 1 2.We note your presentation of operating costs and administrative and commercialization expenses, excluding depreciation, and operating costs and administrative and selling expenses, excluding depreciation, presented on a consolidated basis. Tell us how you considered Regulation G with respect to the presentation of the foregoing measures. Analysis of the Results, page 3 3.We note your presentation of operating profit before depreciation on a segment basis here. However, a similar presentation is not included in the segment disclosure in Note 8 to the financial statements on page 11 of the Form 6-K filed August 16, 2022. Therefore, clarify to us whether you consider operating profit before depreciation a measure of segment profit or loss pursuant to IFRS 8. 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 Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or Kimberly Calder, Assistant Chief Accountant, at (202) 551-3701 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
October 31, 2022
Alejandro M. Basso
Chief Financial Officer and Services Vice President
Gas Transporter of the South Inc.
Don Bosco 3672, 5th Floor
C1206 ABF City of Buenos Aires, Argentina
Re:Gas Transporter of the South Inc.
Form 20-F for Fiscal Year Ended December 31, 2021
Filed April 26, 2022
Form 6-K Filed August 9, 2022
File No. 001-13396
Dear Alejandro M. Basso:
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 Fiscal Year Ended December 31, 2021
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Year 2021 Compared to Year 2020, page 129
1.Please discuss and analyze material changes to your balance sheet, and discuss material
events and uncertainties that may impact your future financial condition. Refer to Part 1,
Item 5 of Form 20-F.
FirstName LastNameAlejandro M. Basso
Comapany NameGas Transporter of the South Inc.
October 31, 2022 Page 2
FirstName LastName
Alejandro M. Basso
Gas Transporter of the South Inc.
October 31, 2022
Page 2
Form 6-K Filed August 9, 2022
Second Quarter Ended June 30, 2022, page 1
2.We note your presentation of operating costs and administrative and commercialization
expenses, excluding depreciation, and operating costs and administrative and selling
expenses, excluding depreciation, presented on a consolidated basis. Tell us how you
considered Regulation G with respect to the presentation of the foregoing measures.
Analysis of the Results, page 3
3.We note your presentation of operating profit before depreciation on a segment basis
here. However, a similar presentation is not included in the segment disclosure in Note 8
to the financial statements on page 11 of the Form 6-K filed August 16, 2022. Therefore,
clarify to us whether you consider operating profit before depreciation a measure of
segment profit or loss pursuant to IFRS 8.
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 Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or Kimberly
Calder, Assistant Chief Accountant, at (202) 551-3701 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation