SecProbe.io

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                                 STENA AB (PUBL)
                                 Masthuggskajen
                               S-405 19 Gothenburg
                                     Sweden

September 14, 2005

VIA EDGAR
Mr. Michael Fay
Branch Chief
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20545

                          RE:  Stena AB Form 20-F for the fiscal year ended
                               December 31, 2004 (File No. 033-99284)
                               --------------------------------------------

Dear Mr. Fay:

         We have reviewed your letter dated August 4, 2005 (the "Comment
Letter") regarding Stena AB's (the "Company") annual report on Form 20-F for
the fiscal year ended December 31, 2004. For the convenience of the staff (the
"Staff") of the Securities and Exchange Commission (the "Commission"), each
response has been numbered to correspond with the comments in the Comment
Letter.

Form 20-F for the fiscal year ended December 31, 2004
-----------------------------------------------------

Significant Events, page 48
---------------------------

1.   We note the acquisition of Drott AB on August 10, 2004 and Blomsterlandet
     in April 2004. Please tell us how you have evaluated the significance of
     these acquisitions under Regulation S-X, Article 03-05(b)(2). If either of
     these businesses is significant (individually or in the aggregate) to your
     business under the significance tests noted in the regulation, you should
     submit the required audited U.S. GAAP financial statements or U.S. GAAP
     reconciliation and pro-forma financial statements as required. We note that
     if required, this information was due within 75 days of the acquisition.
     For guidance, refer to Regulation S-X, Article 03-05 and Regulation S-X,
     Article 11.

     Response
     --------

In connection with the registration statement on Form F-4 that we filed with the
Commission on December 20, 2004 we evaluated the significance of these
acquisitions under Regulation S-X, Article 03-05(b)(2) using US GAAP financial
information for the financial year 2003. The outcome of our significance testing
was that Bostads AB Drott represented 10.1 %, 28.4 % and 25.8%, respectively of
the total investments, total assets and income from continuing operations before
income taxes of the Stena group for the financial year 2003. As such, the
registration statement on Form F-4 included the requisite financial statements
and pro forma financial information for Bostads AB Drott. The corresponding
calculation for Blomsterlandet was 1%, 1% and 0%. As such, no financial
statements (or pro forma financial information) for Blomsterlandet was required
to be included in the registration statement on Form F-4.

We advise the staff that as a foreign private issuer that files periodic reports
on Forms 20-F and 6-K, we are not required to file a Form 8-K for our business
acquisitions. Therefore we are only subject to the requirements of Regulation
S-X, Article 3-05 when we file a registration statement.

Long-Term Financial Obligations and Other Contractual Obligations, page 60
--------------------------------------------------------------------------

2.   We note your acquisition of the Swedish chain store "Blomsterlandet" in
     April 2004. As part of this acquisition, an additional SEK 26 million is to
     be paid in 2009. It appears that this additional payment is not included in
     your table of contractual obligations. Please ensure that this obligation
     is included in the table in future filings.

     Response
     --------

We advise the staff that the SEK 26 million is included in Other non-current
liabilities in the table on page 60, mistakenly in the column "More than 5
years" instead of in the column "4-5 years". We will correct this in future
filings.

Revision of Depreciable Lives of Vessels, page 61
-------------------------------------------------

3.   Please tell us the factors considered in making the determination that
     useful lives of your RoRo vessels and tankers should be extended from 15
     years to 20 years.

     Response
     --------

As of January 1, 2004, we conducted a review of the estimated useful lives of
our vessels. As a result of this review, new useful lives of 20 years (instead
of 15 years) were established for both RoRo vessels and tankers based upon both
extended technical life-times and the fact that we sold a number of vessels in
recent years at prices well above net book value, indicating that our previous
estimated useful lives were too short. Also, our new RoRo vessels have been of
similar design and standards as RoPax vessels, which are depreciated over 20
years.

Note 1- Summary of Accounting Principles, page F-7
--------------------------------------------------

New Accounting Principals, page F-7
-----------------------------------

4.   We note your disclosure that you consolidated two financial investments
     according to the equity method as of January 1, 2004. Please tell us why it
     was appropriate to consolidate these two investments, clarify for us how
     you previously accounted for the investments and clarify how you are
     currently accounting for the investments. In this regard we note that under
     U.S. GAAP, investments accounted for under the equity method are not
     consolidated in a company's financial statements.

     Response
     --------

We began accounting for these investments in 2004 in accordance with the equity
method under Swedish GAAP due to our implementation of a new accounting
principle as of January 1, 2004. Prior to 2004, these investments had been
recorded at cost and viewed as investments in an investment fund. Under US GAAP,
these financial investments are variable interest entities (VIEs) as defined by
the FASB in FIN 46R. Accordingly, the VIEs are consolidated for US GAAP
purposes. Please refer to page F-50 note (l) and page F-54 note (f) for further
information.

Note 9 - Income Taxes, page F-18
--------------------------------

5.   We note the "Adjustments Previous Years, Rest of the World" for SEK 461
     million in fiscal 2004 and the related explanation regarding the changes in
     legal structure outside of Sweden that made it possible to release prior
     year deferred tax liabilities. Please provide additional explanation
     regarding this legal structuring. Your explanation should include the type
     of legal structuring changes made, the reasons for the legal structuring
     and any additional information regarding guidance you used in determining
     that the related deferred tax liabilities should be released.

     Response
     --------

Since 1996, the Company has leased certain HSS vessels (the Stena Explorer and
Stena Voyager) from two special purpose leasing entities. The leases were each
accounted for as capital leases and accordingly, the Company recorded an asset
and a corresponding lease obligation on its balance sheet for both Swedish and
US GAAP purposes. In December 2003, the Company acquired the special purpose
leasing entities. The leasing entities acquired by the Company had deferred tax
liabilities in the amount of SEK 488 million relating to UK taxes. Also in
December 2003, the Company transferred the HSS vessels to a wholly owned
subsidiary which, pursuant to existing tax law, increased the tax basis of the
vessels and reduced the associated deferred tax liabilities at that date. The
effect of the reduction of the deferred tax liabilities for US GAAP purposes was
recorded in 2003 in accordance with EITF Issue 98-11 as an adjustment to the
carrying value of the vessels. In March 2004, proposed changes to existing tax
law were announced in the United Kingdom which, if enacted, would essentially
eliminate the realization of tax benefits from such inter-company transfers of
assets. Under Swedish GAAP, proposed changes in tax law must be taken into
consideration when determining whether a deferred tax liability should be
recognized. Because the Company believed that it was probable that the tax law
would restrict its ability to reduce the deferred tax liability in future
periods, the full amount of the deferred tax liability was recognized in the
December 31, 2003 consolidated balance sheet under Swedish GAAP.

In 2004, management and control of the two leasing entities was moved to The
Netherlands and the tax residency was transferred from the UK to The
Netherlands. As a result, the Company was able to release the UK deferred tax
liabilities, as the leasing entities were no longer subject to UK taxes. Under
Swedish GAAP, the release of the UK deferred tax liabilities in the amount of
SEK 488 million was recorded as an income tax benefit in 2004. As discussed
above, the effect of the release in deferred tax liabilities for US GAAP
purposes was recorded in 2003 as an adjustment to the carrying value of the
vessels. In addition to the SEK 488 million, there were offsetting adjustments
of SEK (27) million relating to the tax for previous years outside of Sweden.
Please refer to page F-50 note (k) for further information.

Note 10 - Intangible Fixed Assets, page F-20,
---------------------------------------------

6.   We note your transfer into intangible fixed assets of SEK 223 million in
     fiscal 2004; however, it is not apparent from your explanation why it was
     necessary to transfer amounts previously accounted for as equipment to
     intangible fixed assets. Please provide additional explanation regarding
     the reason for the transfer. In addition, we note a transfer out of fixed
     assets in Note 11 of only SEK 128 million. As part of your response,
     explain the discrepancy between amounts transferred out of fixed assets and
     into intangible fixed assets.

     Response
     --------

Computer hardware and computer software were previously characterized as
Equipment, a tangible fixed asset. In connection with material investments in
2004 for new integrated business solutions such as management control systems
and a new ferry operation booking system, we decided to reclassify such computer
software to intangible fixed assets in accordance with Swedish GAAP. The
acquisition cost and accumulated amortization of the assets reclassified was SEK
223 million and SEK (87) million, respectively. The computer hardware is still
included as Equipment.

The transfer out of cost of Equipment is SEK (140) million, of which SEK (223)
million is described above and SEK 83 million was transferred from current
assets to Equipment, mainly representing spare parts for vessels, which was
previously recorded as Inventories. Swedish GAAP allows the treatment of spare
parts either as Inventories or Equipment. Due to the increased integration of
these spare parts with the vessels, the transfer to Equipment was chosen as the
preferable method.

Note 31 - U.S. GAAP Information, page F-46
------------------------------------------

General
-------

7.   Form 20-F, Item 17 instructions requires a quantified description of
     balance sheet differences under Swedish GAAP in comparison to U.S. GAAP.
     There are several ways which this information may be provided, one of
     which is a reconciliation of stockholders' equity under Swedish GAAP to
     stockholders' equity under U.S. GAAP. In this regard, we note that the
     reconciliation of stockholders' equity should be in sufficient detail to
     allow an investor to determine the differences between a balance sheet
     prepared using foreign GAAP and one prepared using U.S. GAAP. Adjustments
     that impact several balance sheet items should not be presented as one
     reconciling item unless the impact on each balance sheet item is
     appropriately discussed in the explanation of your adjustment. In
     addition, adjustments should be reflected at the subsidiary level to
     determine the impact on items such as minority interest, taxes and
     currency translation. Please review instructions to Item 17, Form 20-F
     and amend your filing to disclose the impact to individual balance sheet
     items.

     Response
     --------

We believe that the current description gives the reader the ability to
reconcile any differences on the balance sheet from Swedish GAAP to US GAAP.
However, in response to the Staff's comment and to more clearly present the
differences in the balance sheet amounts we will in future filings include a US
GAAP balance sheet.

8.   Please amend Note 31 of your Form 20-F to reflect material income statement
     classification differences had your statements been prepared under U.S.
     GAAP. Specifically, the classification of gain on sale of vessels' should
     be classified as other income instead of a component of revenue.

     Response
     --------

In response to the Staff's comments, we will in future filings include a
description of material income statement classification differences.

With regards to the gains on sale of vessels, it should be noted that disposed
assets may have different carrying values under US GAAP resulting in a different
gain or loss on sale than under Swedish GAAP. Also, a disposal of an asset
resulting in a gain in accordance with Swedish GAAP may not qualify for a sale
under US GAAP (e.g. certain sale-lease back transactions). Please refer to page
F-48 note (a) for further information.

9.   Please amend Note 31 of your Form 20-F to include a cash flow statement
     prepared under U.S. GAAP or IAS 7, as amended. You may also consider
     providing a reconciliation of your cash flow statement or statement of
     financial position that quantifies the material differences in the
     statement presented as compared to U.S. GAAP, in lieu of the U.S. GAAP or
     IAS 7 cash flow statement. For additional guidance, refer to Form 20-F,
     Item 18 instructions.

     Response
     --------

The cash-flow statements on page F-6 are prepared in accordance with SFAS 95
which is accepted under Swedish GAAP since it essentially gives the same
information as the cash-flow statement required under Swedish GAAP. We believe
that our cash-flow statements materially comply with SFAS 95 and no amendment to
our Form 20-F is necessary. We advise the Staff that cash flows from trading
securities is presented net in the cash flow statement but the gross amounts are
presented in Note 6. In addition, disclosures of cash paid for income taxes and
interest are included in Notes 9 and 32(d), respectively.

10.  Please provide a statement of comprehensive income which separately
     identifies net income and the components of other comprehensive income for
     each year in which a balance sheet is presented in accordance with SFAS
     130.

     Response
     --------

In response to the Staff's comment we will in future filings provide a statement
of comprehensive income in accordance with SFAS 130 for each year in which a
balance sheet is presented.

Note 31 - U.S. GAAP Information, page F-46
------------------------------------------

Note (f), page F-49
-------------------

11.  We note your adjustment to reflect the purchase accounting for the Stena
     Line. Please amend your Form 20-F to include a separate adjustment for each
     line item impacted by the acquisition. Adjustments that impact several
     balance sheet items should not be presented as one reconciling item.

     Response
     --------

We advise the staff that the adjustment to reflect the purchase accounting was
separated as an adjustment for each line item impacted by the acquisition at the
time of the acquisition. The only adjustment that remains relates to the
negative goodwill recorded in connection with the Stena Line acquisition. Under
Swedish GAAP, the negative goodwill has been amortized into income over 4 years.
Under US GAAP, the negative goodwill was us