SecProbe.io

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Mail Stop 3561

      							July 13, 2005

Via U.S. Mail and Fax (212-450-3519)

Mr. Jose Fermin Alvarez
Chief Financial Officer
Telefonica Del Peru S.A.A.
Avenida Arequipa 1155
Santa Beatriz
Lima, Peru

	Re:	Telefonica Del Peru S.A.A.
      Form 20-F for the Year Ended December 31, 2004
		File No. 001-14404

Dear Mr. Alvarez:

      We have reviewed your 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. 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 or may not
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.

Form 20-F for the Year Ended December 31, 2004
Financial Statements and Notes

Note 4. Significant Accounting Policies and Practices

(n) Revenues, costs and expenses recognition
1. Please disclose and explain to us your Peruvian GAAP revenue
recognition policies for products and services offered by your
business communications and cable television businesses.

Note 11. Other Accounts Receivable, Net, page F-25

2. It appears from the disclosure in Note 11(a), that for Peruvian
GAAP purposes, you have recognized receivables representing claims
for the return of funds illegally seized by various municipalities
in
Lima and provinces.  Please disclose the facts and circumstances
of
these seizures and advise us.  Also, explain to us how you have
accounted for the seizures and your basis for this accounting
under
US GAAP.  If you did not recognize a charge to earnings when funds
were disbursed you should explain why and how this accounting
complies fully with the guidance in SFAS No. 5.  Since apparently
the
return of the seized assets is contingent upon the seizures being
declared illegal, we question your basis for recognizing a
receivable
under US GAAP.  Please note, for US GAAP purposes, contingencies
that
may result in gains should not be reflected in the financial
statements.  Please revise your US GAAP financial information
accordingly or advise us.  In your response to this comment please
tell us if these receivables represent legally enforceable claims
for
payment as of the balance sheet date.

Note 14. Property, Plant and Equipment, Net, page F-30

(d) Impairment Loss

3. Please disclose your US GAAP policies for recognizing and
measuring impairments in the value of long-lived assets.  It
appears,
from your disclosure in Note 14 (d), under Peruvian GAAP you
recognize a valuation allowance (S/.79,192,000 as of December 31,
2004).  Under US GAAP you should record an impairment loss as a
reduction in the cost basis of the impaired asset.  Refer to
paragraph 15 of SFAS No. 144.
Note 22.Transaction with Related Parties, page F-39
4. With a view towards expanding your policy disclosure, please
explain to us your accounting policy for shared service centre
expenses under Peruvian GAAP.  If your Peruvian GAAP accounting
policies for these expenses differs from what is required under US
GAAP, please tell us how and where you have reflected the
difference
in the US GAAP financial information in Note 35.  Refer to SAB
Topic
1B.  Also, clarify for readers why the amounts reported for 2003
and
2004 in this Note are not the same as the amounts shown on the
face
of the financial statements.

Note 29. Other Income (Expenses), Net, page F-50

5. The nature of the other expenses reported in the line item
"provisions and prior years` expenses" and your basis for your
accounting is unclear, please advise us and clarify your
disclosures.

Note 34. Contingencies, pages F-58 - F-59

6. We note the contingency disclosure provided in Note 34.  For US
GAAP reporting purposes please provide all of the disclosures
required by SFAS No. 5.  With respect to the contingencies
disclosed
in Note 34(a), please quantify the total amount of taxes that the
taxing authorities claim the company owes, the amount of
reasonably
possible unasserted claims, and the total amount accrued by the
company under US GAAP.  You should also disclose the amount of
reasonably possible loss in excess of the amount accrued.  In this
regard, we note you did not quantify in paragraphs (a)(iii) and
(a)(iv) of Note 34 the amounts claimed to be owed by the Company
and
you did not address the possibility of owing additional taxes for
years subsequent to 2000. With respect to the contingencies
disclosed
in Note 34(b), you should provide separate, comprehensive
disclosure
for each significant contingency.  In addition, for all
contingencies, the disclosed amounts of your US GAAP loss accruals
should be on a gross basis, before adjustments to recognize the
present value of the disbursements.  Also, please disclose the
timing
of the expect disbursements.

7. Please explain to us in detail your US GAAP accounting for the
contingent tax liabilities and how you applied the guidance in
SFAS
No. 5 and FIN 14 when estimating and accruing the contingent tax
liability.  In this regard, we note in Note 4(m) under Peruvian
GAAP
"[a] provision is recognized only when ... amount is able to be
determined."  Recording an accrual only when you are able to
determine a specific amount appears to a higher standard than the
US
GAAP requirement to accrue the most likely loss amount within the
range of reasonably possible amounts.  We refer you to the
guidance
in paragraphs 2 and 3 of FIN 14.

8. We note in Note 34(a) management`s separate representations
concerning the significance of each tax assessment.  Since the tax
claims seem to be similar in nature, please disclose management`s
assessment of materiality of the tax liabilities in their totality
in
your US GAAP contingent liability disclosures.  In addition, your
materiality assessment should separately address the potential
impact
of the taxes on both the Company`s financial position and future
results of operations.

Note 35. Summary of Differences Between Accounting Principles
Generally Accepted in Peru (Peruvian GAAP) and Accounting
Principles
in the United States (U.S. GAAP), pages F-59 - F-73

9. It appears, from the disclosure on page F-62, that the U.S.
GAAP
balance sheet amounts have been restated.  If so, disclose in
detail
the nature of the restatement and its impact on previously
reported
amounts, and advise us.  Refer to the disclosure guidance in FASB
No.
154 and explain to us your consideration of this literature.

(b) Revenue Recognition, page F-66

10. We note on page F-18 that, under Peruvian GAAP, revenues and
costs from telephone line installation are recognized at the time
the
related contracts are signed.  It is unclear if you address your
accounting for this service in your US GAAP reconciliation since
in
the disclosure in Note 35(b) you disclose that under Peruvian GAAP
installation fees and related costs are recognized when
installation
is made.  Please expand your US GAAP revenue recognition policy
disclosure to clearly address your treatment of this difference in
accounting and to explain your US GAAP policy.

*    *    *    *
      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Andrew Mew, Staff Accountant, at (202) 551-
3377
or Robert S. Littlepage, Jr., Accounting Branch Chief, at (202)
551-
3361 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3810
with any other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

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Mr. Jose Fermin Alvarez
Telefonica Del Peru S.A.A.
July 13, 2005
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