SecProbe.io

March 20 , 2013

Via E-mail
Mr. Jonathan Symonds
Chief Financial  Officer
Novartis AG
CH-4056 Basel
Switzerland

Re: Novartis  AG
  Form 20-F for Fiscal Year Ended December 31, 201 2
  Filed January 23, 2013
File No. 001-15024

Dear  Mr. Symonds :

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.
In our comment s, we ask you to provide us with information so we may better understand
your disclosure.

Please respond to this letter within 10 business days by  providing the requested
information or by advising us when you will provide the requested response.   If you do
not be lieve a comment applies to your facts and circumstances, please tell us why in your
response.   Please furnish us a letter on EDGAR under the form type label CORRESP that
keys your response s to our comment s.

After reviewing the information provided, we m ay raise additional comments
and/or request that you amend your filing.

Item 18. Financial Statements
Notes to Consolidated Financial Statements

1. Significant Accounting Policies
Intangible Assets Available For Use, F -11

1. Your disclosure herein suggests that amortization of currently marketed products,
marketing know -how, and a portion of technologies  classified as cost of goods
sold are accounted for as inventoriable costs.   Please tell us if our understanding is
correct, and provide us proposed revisio ns to your inventories accounting policy
note on F -14 to be included in future filings that explicitly  identifies which of
these intangible assets’ amortization is included as an inventoriable cost.   Please

Mr. Jonathan Symonds
Novartis AG
March  20, 201 3
Page 2

 also provide us an analysis of each aspect includ ed within these three categories
that supports your accounting treatment of amortization as inventoriable costs
under IAS 2.   For example, your description of the categories suggests there are
four parts that comprise the value of currently marketed produc ts, two parts that
comprise the value of marketing know -how and that there may be three types of
know -how for technologies (i.e. research, development and production).

Contingent Consideration, page F -15

2. Please explain to us the factors governing you r recognition of contingent
payments “outside of a business combination,” which you appear to record only
when they become “unconditional.”  Refer us to the technical guidance upon
which you have relied.

4. Associated Companies, page F -31

3. Regarding your accounting for your investment in Roche Holding AG, p lease
provide us the following information:

 Tell us how your use of a survey of analyst estimates of Roche’s net
income to estimate your share of its earnings complies with the guidance
in paragra phs 24 and 25 of IAS 28, revised in 2003.  In your response,
please tell us the amount of any adjustments recorded in 2012 to correct
your estimate at December 31, 2011 and the amount of any adjustments
you will record in 2013 to correct your estimate at D ecember 31, 2012.  In
addition, please tell us why you changed the presentation of the second
table on page F -32 to remove the prior -year adjustment line item existing
in the corresponding table of your Forms 20 -F in 2011 and earlier.
 Tell us how the accum ulated equity accounting adjustments reflect the net
income effect and dividends received for each year presented.  In your
response, please tell us why the dividends you received from Roche are
not effectively included in your share of its net assets and why the equity
accounting adjustments are not reflected in your share of the re -appraised
intangible assets and implicit goodwill.
 Tell us how the change in “Novartis share of re -appraised intangible
assets” relates to the amortization of fair value adjust ments, net of taxes.
 Tell us your consideration of profits/losses from upstream and
downstream transactions in accounting for your collaborations and other
arrangements with Roche, as discussed in paragraph 22 of IAS 28, revised
2003.

Mr. Jonathan Symonds
Novartis AG
March  20, 201 3
Page 3

 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 the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.   Since the compa ny
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 responding to our comments, please provide  a written statement from the
company acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to  the filing; 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.

Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660  or Mark
Brunhofer, Senior Staff Accountant , at (202) 551 -3638, if you have any questions
regarding th e comment s. In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief
Accountant