SEC Comment Letter for TIM PARTICIPACOES SA (CIK 0001066116) — Sep 23, 2020
TIM PARTICIPACOES SA (CIK 0001066116)
Date: Sept. 23, 2020 · CIK: 0001066116 · Accession: 0000000000-20-008977
AI Filing Summary & Sentiment
File numbers found in text: 001-14491
Letter
United States securities and exchange commission logo September 23, 2020 Adrian Calaza Chief Financial Officer TIM Participacões S.A. João Cabral de Melo Neto Avenue 850-North Tower-12th Floor 22775-057 Rio de Janeiro, RJ, Brazil Re:TIM Participacões S.A. Form 20-F for the Fiscal Year Ended December 31, 2019 Filed May 1, 2020 File No. 001-14491 Dear Mr. Calaza: We have reviewed your August 26, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our July 29, 2020 letter. Form 20-F for the Fiscal Year Ended December 31, 2019 Notes to the Financial Statements Note 26. Net revenue, page F-71 1.Please revise to disclose that gross operating revenue as presented is a required disclosure pursuant to Brazilian Corporations Law and permitted by the Comissão de Valores Mobiliários (the “CVM”). Refer to IAS 1, paragraph 112(c). 2.We note your response to prior comment 1. While we understand that disclosure of gross operating revenue is required by Brazilian Corporations Law, it is not clear why you include it in your discussion of operating performance within Item 5.A. Operating Results of your Form 20-F. Please explain.
FirstName LastNameAdrian Calaza Comapany NameTIM Participacões S.A. September 23, 2020 Page 2 FirstName LastName Adrian Calaza TIM Participacões S.A. September 23, 2020 Page 2 You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Christine Dietz, Senior Staff Accountant at (202) 551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
September 23, 2020
Adrian Calaza
Chief Financial Officer
TIM Participacões S.A.
João Cabral de Melo Neto Avenue
850-North Tower-12th Floor
22775-057 Rio de Janeiro, RJ, Brazil
Re:TIM Participacões S.A.
Form 20-F for the Fiscal Year Ended December 31, 2019
Filed May 1, 2020
File No. 001-14491
Dear Mr. Calaza:
We have reviewed your August 26, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
July 29, 2020 letter.
Form 20-F for the Fiscal Year Ended December 31, 2019
Notes to the Financial Statements
Note 26. Net revenue, page F-71
1.Please revise to disclose that gross operating revenue as presented is a required disclosure
pursuant to Brazilian Corporations Law and permitted by the Comissão de Valores
Mobiliários (the “CVM”). Refer to IAS 1, paragraph 112(c).
2.We note your response to prior comment 1. While we understand that disclosure of gross
operating revenue is required by Brazilian Corporations Law, it is not clear why you
include it in your discussion of operating performance within Item 5.A. Operating Results
of your Form 20-F. Please explain.
FirstName LastNameAdrian Calaza
Comapany NameTIM Participacões S.A.
September 23, 2020 Page 2
FirstName LastName
Adrian Calaza
TIM Participacões S.A.
September 23, 2020
Page 2
You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Christine Dietz,
Senior Staff Accountant at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology