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corresp

October 26, 2011

Chief Accountant’s Office

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention:   Mr. Terence O’Brien, Chief

                   Mr. Alfred Pavot

    Re:

    Asia Pacific Wire & Cable Corporation

Limited (the “Company”) File No. 333-153796

Dear Sirs:

We write on behalf of the Company in connection with its response letter dated as of today’s date
(the “Response Letter”) and submitted herewith in response to the letter of the Commission dated
October 20, 2011 providing certain comments on the Company’s annual report on Form 20-F for the
fiscal year ended December 31, 2010 (the “2010 Form 20-F”).

We wish to confirm the Company’s understanding that the draft disclosure language provided in
paragraph 4 of the Response Letter is for illustrative purposes, in response to the Staff’s request
for sample disclosure, in connection with future filings to be made by the Company. The Company
wishes to confirm that in its future filings it shall provide disclosure, when relevant, that
addresses the methodology employed to calculate DSO, and whether the amounts used, in this case
with respect to accounts receivable, are based upon net or gross amounts.

We wish to clarify also that references in the Response Letter to page F-4 or any other
F-denominated pages refer to the financial statement pages set forth in the audit report of the
Company that forms part of the 2010 Form 20-F.

Please do not hesitate to contact the undersigned if you have any questions with regard to the
foregoing or the Response Letter. Thank you for your attention to this matter.

Very truly yours,

Michael J. Hagan

cc: Mr. Frank Tseng, Chief Financial Officer

    Michael.Hagan@ThompsonHine.com Fax: 212.344.6101 Phone: 212.908.3916

    MH:cl 210611.1

    Asia Pacific Wire & Cable Corp Ltd

Quoted on the New York OTC Bulletin Board

7/FI. B, No. 132, Sec. 3, Min-Sheng East Road, Taipei, 105,
Taiwan

Tel: 886(2) 2712 2558 Fax: 886(2) 2712 3557

October 26, 2011

By
Email: (PavotA@SEC.GOV), and U.S. Mail

By Edgar

Terence O’Brien

Accounting Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable Corporation Limited (the
“Company”) File No. 333-153796

Dear Mr. O’Brien:

This letter is in reply to your letter of October 20, 2011, which commented on the Form 20-F
filed by the Company for the fiscal year ended December 31, 2010. Please find our responses below.
Our paragraph numbering corresponds to the paragraph numbers in your October 20, 2011 letter.

1. Duly noted and the Company wishes to confirm that it shall comply with this comment.

2. Duly noted and the Company wishes to confirm that it shall apply with this comment.

3. In calculating the DSO data on page 55, we used gross
accounts receivable as the basis for
our results, while on page 48 we used net accounts receivable, by which we mean net of
estimated allowance for doubtful accounts. While gross accounts receivable increased by 37% in
2010, net accounts receivable only increased by 21%. As the annual and 4th quarter sales increased
by 30% and 6%, respectively, the DSO based on net accounts receivable accordingly decreased. In
future, we will conform our methodologies to avoid confusion.

4. We will expand disclosure in future filings to address whether an increase in accounts
receivable, if one then exists, has been impacted by an increase in the aging of our receivables
portfolio and/or changes in our revenue recognition policies. We would propose the following draft
disclosure pertaining to our 2010 financial statements: “The gross accounts receivable at the end
of fiscal year 2010 increased by 37% when compared with 2009. However, the DSO, when calculated
using net accounts receivable, increased by only 21%. In addition, our DSO is calculated using
average accounts receivable across the reporting period. That is, we
take the A/R amount at the
beginning of the year and the A/R amount at the end of the year and divide the sum of those two
amounts by 2. We believe that this approach makes most sense. As annual

Terence O’Brien

Division of Corporation Finance

U.S. Securities and Exchange Commission

October 26, 2011

Page 2

and fourth quarter sales increased by 30% and 6%. respectively, the DSO in 2010 actually
decreased from 2009 and the increase in accounts receivables is attributable to increased sales.
The aging of our accounts receivable portfolio remained comparable
with that of 2009 and there
were no changes with regard to revenue recognition policies.” For your reference, we attach a
spreadsheet which we believe may be helpful in conveying the Company’s determinations on this
point.

5. Duly noted and the Company wishes to confirm that it shall comply with this comment.

6. As the Staff is aware, the Company’s reporting currency is U.S. dollars. Each of the
Company’s operating subsidiaries generates revenues in the local currency of the jurisdiction
in which it operates and similarly incurs most of its expenditures in that local currency, and the
functional currency of each such subsidiary is its local currency. For consolidation purposes, the
Company translates the balance sheets of the subsidiaries using the prevailing exchange rates as
of balance sheet date as specified in ASC 830. Differences arising from the process of translating
each operating subsidiary’s balance sheet into U.S. dollars are included in a separate component
of equity. An exchange realignment arises as a result of the movement of the exchange rate for the
functional currency compared with U.S. dollars of each subsidiary and the carrying amount of
property, plant and equipment in the consolidated balance sheet
reported in U.S. dollars
incorporates such exchange realignment. In 2010, the Company recorded depreciation expense
amounting to $6,857, a net increase in accumulated depreciation based on exchange realignment
of $15,772 and disposal of property, plant and equipment with accumulated depreciation amounting to
$1,188 up to the date of disposal of each item. Accordingly, the increase in accumulated
depreciation during 2010 was $21,441, as reported on page F-4.

Purchases of property, plant and equipment amounted to $3,653 in 2010. The Company had a net
increase of $19,281 due to exchange realignment and disposed of property, plant and equipment
initially acquired for $1,232. In total, gross property, plant and equipment increased by
$21,702, as reported on page F-4.

With regard to our future filings, we note that material non-cash investments and
financing activities are required disclosures.

On behalf of the Company, I acknowledge that:

    •

    should the Commission or the Staff, acting pursuant to delegated authority, declare a filing
effective, it does not foreclose the Commission from taking any action with respect to the
filing;

Terence O’Brien

Division of Corporation Finance

U.S. Securities and Exchange Commission

 October 26, 2011

Page 3

    •

    the action of the Commission or the Staff, acting pursuant to delegated authority, in
declaring a filing effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in such filing; and

    •

    the Company may not assert Staff comments and the declaration of effectiveness as a defense
in any proceeding initiated by the Commission or any person under the federal securities laws
of the United States.

Thank you for your attention to this matter.

Please do not hesitate to contact us if you have any further questions with regard to this matter.

Sincerely yours,

Frank Tseng

Chief Financial Officer

Asia Pacific Wire & Cable Corporation Limited

    cc:

    Mr. Alfred Pavot, Division of Corporate Finance, U.S. Securities and
Exchange Commission
Michael J. Hagan, Esq.

Annex
A DSO Data

1: Page 55 differs from page 48

2: To provide the calculation

    DSO

    2010

    2009

    Page 48

    95.8

    99.6

    used Net AR to calculate

    Page 55

    102

    109

    used Gross AR to calculate

Calculation:

    Days sales outstanding is calculated as:

    Average net accounts receivable

    x

    365 days

    Total credit sales (total sales)

    2010

    2009

    +/-

    %

    2009

    2008

    +/-

    %

    Gross accounts receivable

    151,340

    110,543

    40,797

    37
    %

    110,543

    105,545

    4,998

    5
    %

    Provision for doubtful accounts

    (6,886
    )

    (8,694
    )

    1,808

    (8,694
    )

    (9,644
    )

    950

    Net accounts receivable

    144,454

    101,849

    42,605

    101,849

    95,901

    5,948

    2010

    2009

    +/-

    %

    2009

    2008

    +/-

    %

    Net sales

    469,330

    362,231

    107,099

    30
    %

    362,231

    500,798

    (138,567
    )

    -28
    %

    Average net accounts receivable

    123,152

    98,875

    24,277

    25
    %

    Average gross accounts receivable

    130,942

    108,044

    22,898

    21
    %

    (opening + closing)/2

    DSO (based on net AR — page 48)

    95.8

    99.6

    DSO (based on gross AR — page 55)

    102

    109

Days Sales Outstanding — DSO

Days sales outstanding is calculated as: