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Letter of Correspondence

 July 8, 2005

 BY EDGAR

 Tracie Towner

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Mail Stop 04-05

 Washington, D.C. 20549-0405

 Re:

Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2004 of

Stora Enso Corporation (File No. 1-15112)

 On behalf of our
client, Stora Enso Corporation (the “Company”), we are submitting this letter in response to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) that were contained in the
Staff’s letter to Mr. Esko Makelainen of the Company dated June 8, 2005 (the “Comment Letter”).

 Set forth below are the responses of the Company to the Staff’s comments in the Comment Letter. For ease of reference, each comment contained in the
Comment Letter is printed below in bold and is followed by the Company’s response. Please note that we have also set forth below the text of the language that we propose to make in the Company’s amendment to its Form 20-F for the year
ended December 31, 2004 that the Company proposes to file once all of the Staff’s comments have been resolved.

 20-F for the year ended December 31, 2004

 Operating and Financial Review and Prospects

 Financial Items, page 56

1.
We note your disclosure that indicates you terminated your cross-border leasing contracts in the United States. Please tell us the nature, amounts, terms, and authoritative
literature used to account for these contracts under both IFRS and U.S. GAAP.

 In 1996 two paper machines owned by Stora Enso North America (SENA) were sold to three financial
institutions in the United Kingdom (UK), and SENA subsequently leased those paper machines in the form of six leases. Our sale-leaseback transactions were intended to serve as UK tax leasing arrangements for the financial institutions (Lessors),
while providing SENA with financing that included an up front cash payment. A portion of that cash was to be used by SENA to pay down higher interest rate debt.

The assets were carried at a book value of $315 million and sold for cash payments totalling $422 million, resulting in an unrecognized gain on the
transactions of $107 million. Simultaneous to the sale, SENA leased the machines back for a primary term of 30 years, with semi-annual payments based upon the fair market rental value of the equipment as determined by an appraisal firm, which
accrued interest at rates based on UK LIBOR. SENA was also required by the Lessors to establish and maintain sterling denominated restricted cash balances in the initial total amount of $393 million, which represented a percentage of the total lease
obligations at inception of the leases, based an assumption of UK LIBOR approximating 9% over the term on the leases.

 After evaluating the terms of the lease, due to the transfer of ownership of the property to SENA by the end of the lease term, we determined that the
leases met certain of the criteria included in paragraph 7 of SFAS 13 Accounting for Leases and paragraph 10 of IAS 17 Leases, which resulted in our company recording leased assets and corresponding lease obligations amounting to the
present value of minimum lease payments. In addition, we deferred the gain on the sale of our paper machines pursuant to EITF 89-20 Accounting for Cross Border Tax Benefit Leases and paragraph 59 of IAS 17.

 From the late 1990s, Inland Revenue, the UK taxing authority, had challenged
various UK financial institutions regarding their tax treatment of finance leases. SENA and the Lessors determined in late 2003 that the structure of the leases would no longer result in the benefits originally intended by the parties to the
agreements. This was due in part to average LIBOR rates being substantially less than the originally anticipated 9%, UK tax rates having declined since the origination of the contracts and the changing interpretation by Inland Revenue of tax rules
regarding leasing in the United Kingdom.

 After a series of
discussions, on November 5, 2003, the Inland Revenue proposed a settlement offer to the Lessors and to SENA which allowed for the termination of the leases in a manner which would provide certainty as to the tax treatment of the termination. An
agreement in principle was achieved between the parties on December 11, 2003, subject to determination of final amounts and formal documentation. By accepting the settlement, the Lessors and SENA agreed to terminate the leases in accordance with the
original terms of the leases. The settlement allowed the Lessors to claim partial depreciation of the leased assets and resolved all open Inland Revenue audit inquiries with the Lessors and SENA. In accordance with the original terms of the leases,
SENA agreed to reimburse the Lessors for all tax costs associated with the lease terminations and other administrative costs associated with the leases.

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 On January 16, 2004, a final verbal settlement was mutually agreed among the Inland Revenue and the
Lessors. On that date, we estimated that our additional cost for termination of the lease and settlement with the Inland Revenue amounted to $61 million. Since all parties agreed to the settlement offered by Inland Revenue, we believed it was
probable that these amounts would be paid. Because this loss contingency was probable and the amount of the loss could be reasonably estimated, we accrued this amount as of December 31, 2003, which is consistent with the IAS 37 Provisions,
Contingent Liabilities and Contingent Assets and SFAS 5 Accounting for Contingencies. Final payments were made on March 2, 2004 and the leases were terminated in accordance with the settlement agreement.

 Financial Information

 Legal Proceedings and Other Proceedings, page 77

2.
We note that a fine of 21.2 million euros was imposed on your affiliate, Mitsubishi HiTech Paper. Please expand your disclosure to include your determination of the estimated
loss or range of loss you expect to incur and whether you have recorded a related liability. Similarly, please expand your disclosures to address all matters of litigation using the terms defined in Paragraph 3 of SFAS 5.

 We will expand our disclosure of the
Carbonless Paper Case in our 2004 Form 20-F as follows:

 “In 2001, the European Commission issued a decision in which it found companies in the carbonless paper industry, including our affiliated company, Mitsubishi HiTech Paper Bielefeld GmbH, guilty of illegal price-fixing and market
sharing between 1992 and 1997. Mitsubishi HiTech Paper was formerly our wholly-owned subsidiary and was called Stora Carbonless Paper GmbH. Pursuant to the decision of the Commission, a fine of €21.2 million was imposed on Mitsubishi HiTech
Paper. The entire balance of this penalty was paid by the Company in 2002. Further in 2002, Mitsubishi HiTech Paper appealed the Commission’s decision to the European Court of First Instance. As of December 31, 2004, the case and any adjustment
to the penalty originally imposed was still pending with the Court of First Instance. ”

 Additionally, we will expand our disclosure in the 2004 Form 20-F to address all matters of litigation as follows:

 “Competition Law Proceedings

 Inspections of the European and U.S. Competition Authorities and Class-action Lawsuits in the United States. In May 2004, we became
a subject of inspections carried out by the European Commission and the Finnish Competition Authority at certain locations in Europe and received subpoenas issued by the U.S. Department of Justice as part of preliminary anti-trust investigations
into the paper industry in Europe and the United States. The investigations by the authorities in both Europe and the United States are at a fact-finding stage only and no formal allegations have been made against us or any of our employees.

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 Subsequent to the commencement of these antitrust investigations in May 2004, we and
certain of our subsidiaries have been named, along with other producers of paper and forestry products, as defendants in a number of class-action lawsuits brought in U.S. federal and state courts by direct and indirect purchasers of publication
paper. They allege, generally, that the defendants have agreed to fix, increase or maintain the price of publication paper in the United States. They seek unspecified treble damages and, in some cases, restitution for the alleged overcharges
resulting from the alleged violations, including interest and legal costs. There can be no assurances that we will prevail in our efforts to defend against these claims. We do not carry liability insurance which would cover any adverse judgments or
losses resulting from these lawsuits.

 Due to
the considerable uncertainties associated with these matters, it is not possible to estimate the potential loss contingency, if any. No provision has been made with respect to these antitrust investigations by the European and U.S. competition
authorities and class-action lawsuits in U.S. federal and state courts. There can be no assurances that such investigations or lawsuits, if determined adversely to us, would not have a material adverse effect on our business, results of operations
and financial condition.

 Other Proceedings

 Wisconsin Rapids Emissions Case. The EPA has
issued a notice of violation to our Wisconsin Rapids pulp mill alleging that expansions and other capital projects at the mill between 1983 and 1991 violated the U.S. Clean Air Act. The EPA is seeking a penalty of $7.85 million and the installation
of additional air pollution control equipment. See “Item 4. Information on the Company—Environmental Matters.” While we believe that we can assert a number of defenses to these allegations, we have recorded a provision for this loss
contingency.

 Niagara Emissions Case.
The EPA has issued a notice of violation and a finding of violation to our Niagara mill alleging that projects at the mill between 1995 and 1997 violated the U.S. Clean Air Act. No demand has been received from the EPA, but we expect that the EPA
will seek a monetary penalty and the installation of additional control equipment. See “Item 4. Information on the Company—Environmental Matters.” While we intend to defend any case brought by the EPA based upon these allegations, we
have recorded a provision for this loss contingency.

 Appleton Facility Case. Stora Enso North America, Inc. is being sued by M-I, L.L.C. to recover environmental response costs associated with our operations at our former facility at Appleton in the United States and indemnity
provisions contained in agreements between the parties. M-I, L.L.C. most recently operated the drilling fluid business at the site and alleges to have spent $10 million on investigation and remediation at the site. We are unable to reasonably
estimate the amount of potential loss relating to this matter.”

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3.
We note that you recorded a liability in 2003 relating to soil pollution at the Port of Amsterdam. Please expand your disclosure to include the current status of this case
and, if applicable, any payments made and additional liabilities incurred in 2004.

 During 2004 we have negotiated with the Municipality of Amsterdam concerning a settlement in respect of the polluted area. The Municipality has indicated
willingness to accept a settlement and we are currently awaiting their final position. We were not required to make any payments during 2004, nor did we incur additional liabilities. A construction company has made an offer to us to remediate the
area at a price of €1.8 million. Provided the Municipality accepts this solution we would not expect the final costs to go beyond the €2.4 million provided for in our books. In a separate lawsuit we are seeking compensation by way of
indemnification from the contractor who originally delivered the contaminated soil. This court case is still pending in the Court of Appeal and we expect a verdict during 2005.

 We will revise the disclosure in our 2004 Form 20-F as follows:

 “Stora Timber Finance B.V. has been found responsible for soil
pollution at the Port of Amsterdam. As of December 31, 2003 we had a provision of €2.4 million relating to this loss contingency. We are currently negotiating a settlement with the Municipality of Amsterdam. There are no indications the final
cost for such a settlement will go beyond the amount we have accrued. Accordingly, we believe the provision is reasonable. ”

Controls
and Procedures, page 97

4.
We note that you detected an error with respect to the accounting for derivative instruments for U.S. GAAP resulting in a restatement of U.S. GAAP net income in 2002 and 2003.
It is unclear from your disclosure whether you believe this error was the result of a material weakness in your internal controls. Further, you state in the second paragraph that you remediated related controls; however, in the third paragraph, your
disclosure appears to indicate that you are still in the process of reviewing controls to remedy the situation related to derivative instrument accounting. Please revise your disclosure to include a conclusion as to the significance of the weakness
and expand your disclosure to clarify whether or not you believe you have remedied the situation and if so, when you were able to conclude as such. To the extent you do not believe you have completely remedied the situation, provide additional
disclosure as to when you expect your internal issues to be resolved.

 We will revise our disclosure to refer to the control weakness as a material weakness and also to clarify our belief that we remedied the situation prior
to the filing of our Form 20-F in April 2005, as set forth below.

 “Item 15. Controls and Procedures.

 In
connection with the preparation of our annual report on Form 20-F, we detected an error in respect of our accounting for derivative instruments under U.S. GAAP.

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 Consequently, we have restated our net income under U.S. GAAP for the years ended December 31, 2002 and
2003. The restatement relates to the correction of previously reported unrealized gains and resulted in a reduction of our net income under U.S. GAAP for the years ended December 31, 2002 and 2003. See note 31 to our consolidated financial
statements beginning on page F-1 of this annual report. This restatement did not affect our shareholders’ equity under U.S. GAAP. Our financial statements under IFRS did not change as a result of this restatement.

 To remedy the situation and to avoid similar weaknesses in future, prior to
the filing of our annual report on Form 20-F in April 2005, we reviewed our controls related to our reporting for derivative instruments both for content and for purposes of preparing a reconciliation of our financial statements in accordance with
IFRS to U.S. GAAP. We believe that we remedied the material weakness in our internal control over financial reporting in respect of our accounting for derivative instruments under U.S. GAAP prior to April 2005 by improving our review process,
strengthening our understanding of the underlying data for derivative instruments to avoid misinterpretations of such data, and devoting greater review time than previously allocated for such review processes.

 Our president and chief executive officer and our senior executive vice
president and chief financial officer; after evaluating the effectiveness of our disclosure controls and procedures (as defined in Rules 13a-14(c) under the Exchange Act) as of December 31, 2004, have concluded that, as of such date, in light of the
U.S. GAAP reporting for derivative instruments described above (which we have identified as a material weakness and which has been corrected since that evaluation), our disclosure controls and procedures cannot technically be deemed to have been
effective to ensure that material information relating to the Company was made known to them by others within the Company.

 Other than as discuss