SecProbe.io

April 11, 2018
Mats Backman
Chief Financial Officer
AUTOLIV INC
Klarabergsviadukten 70, Section B7, SE-111 64
Box 70381, SE-107 24
Stockholm, Sweden
Re:AUTOLIV, Inc.
Form 10-K for the Year Ended December 31, 2017
Filed February 22, 2018
File No. 001-12933
Dear Mr. Backman:
            We have reviewed your filing 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 10-K for the Year Ended December 31, 2017
Management's Discussion and Analysis of Financial Condition and Results of Operations
Items Affecting Comparability, page 36
1.We note from footnote 1 that your reconciliation adjusts the listed GAAP measures for
capacity alignments and antitrust measures during 2015-2017, separation of your business
segments (2017), and goodwill impairment (2017).  Please revise to separately present
each adjustment to your GAAP measures rather than disclosing them on an
aggregate basis.  Your reconciliations within your earnings release furnished on Form 8-K
should be similarly revised.

 FirstName LastNameMats Backman
 Comapany NameAUTOLIV INC
 June 16, 2017 Page 2
 FirstName LastName
Mats Backman
AUTOLIV INC
April 11, 2018
Page 2
Quantitative and Qualitative Disclosures about Market Risk
Interest Rate Risk, page 57
2.Please clarify your statement in the first sentence of the second paragraph that a one-
percentage point interest rate increase would reduce net interest expense.  It is unclear
why an increase in rates would decrease expense.  Please advise.
Calculation of Leverage Ratio (Dollars in Millions), page 58
3.We note your reconciliation of EBITDA for purposes of your leverage ratio calculation
begins with income before income taxes.  Please be advised earnings is intended to
represent net income as presented on the statement of operations under GAAP.  In this
regard, please revise to begin your EBITDA reconciliation with net income.  Refer to
Question 103.01 of the updated Compliance and Disclosure Iterpretations with respect to
Non-GAAP Financial Measures issued on May 17, 2016 for further guidance.  Your
reconciliation within your earnings release furnished on Form 8-K should be similarly
revised.
Financial Statements
Notes to Consolidated Financial Statements
3. Fair Value Measurements
Assets and Liabilities Measure at Fair Value on a Non-recurring Basis, page 77
4.Please revise to present your disclosures related to the fair-value measurements of assets
and liabilities measures on a nonrecurring basis in a tabular format as required by ASC
820-10-50-8.
            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 Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551-3379
with any questions.
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