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     August 26, 2020

Christine Dietz, Senior Staff Accountant

Frank Knapp, Staff Accountant

Office of Technology

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-7561

    Re:

        TIM Participações S.A.

        Form 20-F for the Year Ended December 31, 2019

        Filed May 1, 2020

        File No. 1-14491

Dear Ms. Dietz and Mr. Knapp:

By letter dated July
29, 2020, you provided comments on behalf of the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “SEC”) with respect to the Annual Report on Form 20-F for the Year Ended December 31, 2019 (the “2019
Form 20-F”) of TIM Participações S.A. (“TIM” or the “Company,” also
referred to in this letter as “we”) filed with the SEC on May 1, 2020, as amended.

Our responses to the
Staff’s comments on the 2019 Form 20-F are set forth below. To facilitate the Staff’s review, we have reproduced the
captions and the numbered comment from the Staff’s comment letter in bold face text. Our response follows the comment.

Form 20-F for
the Fiscal Year Ended December 31, 2019

Notes to the
Financial Statements

Note 26. Net
revenue, page F-71

 1. We note your presentation of gross service revenue, gross goods sold and gross operating revenue on page F-72. Please remove
these non-IFRS presentations from the footnotes as presentation of non-IFRS measures is prohibited in the financial statements
per Item 10(e)(1)(ii)(C) of Regulation S-K. We also note that gross operating revenue is presented on page 75. Please explain your
basis for disclosing this measure as it appears to be a tailored revenue measure. Refer to Question 100.04 of the Non-GAAP Compliance
and Disclosure Interpretations.

Response:

We respectfully acknowledge the Staff’s
comment but believe that inclusion of the measures referred to in the Staff’s comment on the face of the Company’s
financial statements or in the notes thereto is not prohibited by Item 10(e)(1)(ii)(C) of Regulation S-K.

Brazilian Corporations Law No. 6,404/76
Section V, Art. 187 requires that a Brazilian corporation’s income statement for each year shall itemize gross revenue from
sales and services, deductions from sales, rebates and taxes, prior to presenting net revenue. This presentation is further

permitted
by the Brazilian Securities Commission (the Comissão de Valores Mobiliários, the “CVM”),
which is the regulatory body in Brazil responsible for establishing accounting standards and financial reporting obligations for
public companies. Pursuant to the CVM’s official notice of September 1, 2007, a company must present in its income statement,
at a minimum, gross revenue from sales and services, deductions from sales, rebates and taxes, prior to presenting net revenue.
While Item 10(e)(1)(ii)(C) of Regulation S-K would prohibit the presentation of these non-IFRS measures in our financial statements,
Item 10(e)(5) of Regulation S-K clarifies that for purposes of paragraph (e) of Item 10, “non-GAAP financial measures exclude
financial measures required to be disclosed by GAAP, Commission rules, or a system of regulation of a government or governmental
authority or self-regulatory organization that is applicable to the registrant.” [emphasis added] In addition,
while Item 10(e)(5) would require that such financial measures should be presented outside of the financial statements, it makes
exception where such measure is “expressly permitted by the standard-setter that is responsible for establishing the
GAAP used in such financial statements.” [emphasis added] In our case, disclosure of gross service revenue,
gross goods sold and gross operating revenue as part of our financial statements is (1) required by a system of regulation applicable
to us, which is the Brazilian Corporations Law, and (2) expressly permitted by the standard setter that is responsible for establishing
the accounting principles applicable to our financial statements, the CVM.

In addition to being required by Brazilian
law, we believe that the presentation of these metrics is important for understanding our business in comparison to our peers in
the Brazilian telecom industry, who are also required to present this information. Moreover, we believe these metrics are important
for investors to understand our business, as they convey key information related to, among other things, taxes levied on revenues
at the local level as well as relevant discounts provided to telecom clients that can significantly impact our financial statements.
In addition, certain Brazilian taxes to which we are subject, including the Tax on Goods and Services in Circulation (Imposto
sobre Circulação de Mercadorias e Serviços, or ICMS), the Tax on Services (Imposto Sobre Serviços,
or ISS), the Social Integration Program (Programa de Integração Social, or PIS) and the Contribution to Finance
Social Security (Contribuição para Financiamento da Seguridade Social, or COFINS), are calculated based on
gross operating revenues.

Because we believe that presentation of
our non-IFRS measures is permitted pursuant to the guidance in Item 10(e)(5) as being required pursuant to Brazilian Corporations
Law and permitted by the CVM, and due to the importance of such information for analyzing our business in relation to our peers
and in relation to the tax regime and business regime applicable to us, we respectfully inform the Staff that we believe the Company
should be able to continue to include such measure in its annual reports on Form 20-F.

**************

We would like to express
our appreciation for your cooperation in these matters and are available to discuss any of our responses with you at your convenience.
In that connection, please do not hesitate to contact me at +55-21-4009-4000 or Nicholas Kronfeld of Davis Polk & Wardwell
at 212 450 4950, should you have any questions regarding the foregoing.

    Very truly yours,

    /s/ Adrian
Calaza

Adrian
Calaza

Chief
Financial Officer

TIM
Participações S.A.

    cc:

        Nicholas A. Kronfeld (Davis Polk & Wardwell LLP)

        Drew Glover (Davis Polk & Wardwell LLP)

Via EDGAR