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     GlaxoSmithKline
plc

980 Great
West Road

Brentford

Middlesex

TW8 9GS

Tel: +44
(0)20 8047 5000

www.gsk.com

    BY EDGAR

    6 May 2015

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Division of Corporation Finance

Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

United States

    Re:
    GlaxoSmithKline plc (the “Company”) Annual Report on Form 20-F

for the Fiscal Year Ended 31 December 2013 (File
No. 001-15170)

Dear Mr. Rosenberg:

By letter dated 2 April
2015 (the “2 April Comment Letter”), the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) provided certain comments on the Annual Report on Form 20-F for the fiscal year ended 31 December
2014 (“2014 Form 20-F”) (File No. 001-15170) that we filed with the Commission on 27 February 2015.

This letter includes
our responses to the comments contained in the 2 April Comment Letter. For convenience, we have reproduced the Staff’s comments
and provided our responses immediately below.

Mr. Jim Rosenberg, page 2

Exhibit 15.2: GSK Annual Report 2014

Notes to financial statements

Note 14: Taxation, page 156

 1. Please tell us why the reconciling items for differences in overseas taxation rates and the
benefit of intellectual property incentives changed so significantly as a percentage of profit before tax from 2013 to 2014. In
your response, please:

 · identify the significant jurisdictions contributing to the increase in the tax rate associated
with overseas taxes; and

 · describe patent box regimes, explain why they impact your effective tax rate so significantly
in 2014, and quantify their impact on your effective tax rate by significant regime.

The benefit arising from
profits earned in countries with tax rates lower than the UK statutory rate was significantly reduced in 2014 compared with 2013
due to the completion of internal reorganisations of intellectual property ownership, through which the Company moved intellectual
property ownership into the UK from countries with tax rates lower than the UK statutory rate. The countries contributing most
significantly to the increased tax rate were the USA, India, Japan and France.

Patent box regimes provide
a reduced rate of corporate income tax on profits earned from qualifying patents. Since 2012 the Company has centralised Pharmaceutical
intellectual property and product inventory ownership into the UK, following the introduction of a UK patent box regime. The UK
patent box benefit is the most significant element of the total patent box benefit in 2013 and 2014, accounting for nearly 75%
of the total benefit in 2014. The regime is being phased in over a number of years, starting from April 2013, and as a result 2013
does not include a full year of benefit.

Note 18: Goodwill, page 160

 2. In the first paragraph on page 161 you disclose that you use post-tax cash flows and post- tax
discount rates when you utilize value in use in your goodwill impairment testing. Please explain to us how your use of post-tax
inputs in your determination of value in use complies with paragraphs 50 and 55 of IAS 36 which requires estimates of future cash
flows and the discount rate to be determined on a pre-tax basis. Please provide us proposed disclosure to be included in future
periodic reports that asserts in your accounting policy note that the use of post-tax assumptions does not result in a value in
use that is materially different had pre-tax assumptions been used. Also disclose the post-tax and pre-tax discount rates used.

At 31 December 2014,
goodwill was allocated to the eight cash generating units listed on page 161 of the 2014 Annual Report. Of these, seven were valued
applying a fair value less costs of disposal model and only the Japan Pharmaceuticals and Vaccines cash generating unit (CGU) was
valued on a value in use basis. This CGU accounted for approximately 6% of the combined value of all of the CGUs.

Mr. Jim Rosenberg, page 3

The value in use valuation
was initially carried out on a post-tax basis, applying standard discounted cash flow methodology. If a valuation on this basis
were to show a potential impairment or limited headroom, the Company would re-perform the valuation on a pre-tax basis, in order
to determine if an impairment did exist, and, if so, how much it was. Given that a large proportion of the value of the Company
is represented by intellectual property that has little or no value recorded on the balance sheet, management believes that such
potential impairment or limited headroom would be a rare occurrence. At 31 December 2014, the carrying value of the net assets,
including goodwill, that was allocated to the Japan Pharmaceuticals and Vaccines CGU represented approximately 16% of the calculated
post-tax value in use of the CGU, demonstrating significant headroom on this basis.

With effect from 1 January
2015, the Company has changed its segments for the purpose of segmental reporting and expects to perform its impairment testing
for goodwill at the new segment level. The Company now expects that all CGUs will be valued for this purpose on a fair value less
costs of disposal basis. However, if the Company does continue to utilise the value in use basis for the valuation of one or more
CGUs for goodwill impairment testing, in future annual reports, the Company will expand the disclosure presented in the equivalent
of the first paragraph on page 161 of the 2014 Annual Report as follows (new text underlined):

“Value in use is calculated
as the net present value of the projected risk-adjusted post-tax cash flows plus a terminal value of the cash generating unit to
which the goodwill is allocated. Initially a post-tax discount rate is applied to calculate the net present value of the post-tax
cash flows. If the impairment test initially indicates that the value in use of a CGU is close to or below its carrying value,
the test is re-performed using a pre-tax discount rate and pre-tax cash flows in order to determine if an impairment exists and
to establish its magnitude. The discount rate used is based on the Group WACC of 7%, as most cash generating units have integrated
operations across large parts of the Group. The discount rate is adjusted where appropriate for specific country or currency risks.”

The post tax discount
rates utilised in the valuations of the eight CGUs are set out in the table on page 161 of the 2014 Annual Report.

*      *     *

The
2 April Comment Letter sought a statement regarding the following matters from us. Accordingly, we acknowledge that:

 · we are 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

 · we may not assert Staff comments as a defence in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.

Mr. Jim Rosenberg, page 4

If you have any questions
or require additional information with respect to the foregoing, please do not hesitate to contact me.

    	Yours sincerely,

    	/s/ Simon Dingemans

    Simon Dingemans

    Chief
Financial Officer

cc:	       Mr. Frank Wyman, Securities and
Exchange Commission

Mr. Mark Brunhofer,
Securities and Exchange Commission

Mr. Ranjan Sriskandan,
PricewaterhouseCoopers LLP

Mr. Sebastian R.
Sperber, Cleary Gottlieb Steen & Hamilton LLP

Ms. Victoria Whyte,
GlaxoSmithKline plc

Ms. Lisa DeMarco,
GlaxoSmithKline plc

           	Mr. Christopher Buckley, GlaxoSmithKline
plc