SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561

									August 17, 2005

Via US Mail and Facsimile

Mr. Gustavo Castelli
Chief Financial Officer
Quilmes Industrial (Quinsa),
  Societe Anonyme
84, Grand Rue
L-1660 Luxembourg
Grand-Duchy of Luxembourg

		Re:	Quilmes Industrial (Quinsa), Societe Anonyme
			Form 20-F for the fiscal year ended December 31,
2004
			File No. 001-14278

Dear Mr.Castelli:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your document.  Where
indicated, we think you should revise your documents in response
to
these comments in future filings.  If you disagree, we will
consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 15. Controls and Procedures, page 107
1. Please clarify your disclosure and tell us if your officers
concluded that disclosure controls and procedures were effective
as
of the end of the period covered by the report.

Item 17. Financial Statements, page F-1

Note 3. Summary of significant accounting principles and policies,
page F-12

(g) Relationship with PepsiCo, page F-14
2. Please tell us and disclose how and when you recognize the
amounts
paid to PepsiCo based on a percentage of total concentrate
purchases
to support marketing activities.  To the extent that the timing
and
classification of these amounts differ under US GAAP, please
disclose
the nature and amount of this difference in Note 28.  Please also
explain to us your basis under US GAAP and the consideration you
gave
to EITF 02-16.

Note 28.  Differences between Luxembourg GAAP and US GAAP, page F-
37
3. We note the dividends you receive from your subsidiaries are
subject to various restrictions. Please tell us what consideration
you gave to providing condensed financial information of the
registrant as set forth in Rules Rule 4-08 and 12-04 of Regulation
S-
X.    Include in your response the amount of your restricted
retained
earnings.

(b) Impairment of intangible assets, page F-38
4. Please tell us and revise your disclosures to clarify the
differences between accounting for goodwill and intangible asset
impairments under Luxembourg GAAP and US GAAP.  Include the level
at
which you test for goodwill impairment and address how you measure
the amount of impairment loss.  See SFAS 142.

(e) Differences in basis relating to purchase accounting, page F-
39
5. Please advise us and revise your disclosures to quantify the
total
amount of previously recognized goodwill and the amount of the
total
that represents licenses and trademarks qualifying for separate
recognition as identifiable intangible assets with the adoption of
SFAS 142.

      Please send us your response to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter keying your responses to our
comments
and provide any requested supplemental information.  Please file
your
response letter on EDGAR as a correspondence file.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Donna Di Silvio at (202) 551-3202 or, in her
absence, the undersigned at (202) 551-3841 with any other
questions.

Sincerely,

Michael Moran
Branch Chief

??

??

??

??

Mr. Gustavo Castelli
Quilmes Industrial (Quinsa), Societe Anonyme
August 17, 2005
Page 1

</TEXT>
</DOCUMENT>