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    599 Lexington Avenue

    New York, NY 10022-6069

    +1.212.848.4000

By EDGAR

June 22, 2023

Ms. Christina Chalk

Senior Special Counsel, Office of Mergers and Acquisitions

Mr. Blake Grady

Special Counsel, Office of Mergers and Acquisitions

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Banco Itaú Chile

Schedule 13E-3 filed June 6, 2023

Schedule TO-T filed June 6, 2023

Filed by Itaú Unibanco Holding S.A. et al.

File No. 005-80508

Dear Ms. Chalk and Mr. Grady:

This letter responds to the comments contained
in the letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
dated June 16, 2023, with respect to the Tender Offer Statement on combined Schedule TO and Schedule 13E-3
(File No. 005-80508), filed by Itaú Unibanco Holding S.A. (“IUH”) and ITB Holding Brasil Participações
Ltda. (“Purchaser”) with the Commission on June 6, 2023 (the “Schedule TO”), and is submitted on
behalf of IUH and Purchaser. Concurrently with the delivery of this letter, IUH and Purchaser have filed with the Commission an amendment
to the Schedule TO (“Amendment No. 1”).

For the convenience of the Staff, the comments
contained in the Staff’s comment letter appear below in bold. IUH and Purchaser’s response to each comment immediately follows
the applicable comment. Except where indicated otherwise, references in the responses to page numbers are to pages of the U.S. Offer to
Purchase filed as Exhibit (a)(1)(A) to the Schedule TO (the “U.S. Offer to Purchase”). Unless otherwise defined herein, capitalized terms used herein shall have the meaning
given to them in the U.S. Offer to Purchase.

Settlement of the U.S. Offer Price, page iii

 1. We note the disclosure that the Chilean Offer may close before the U.S. Offer
because Chilean law limits the number of days the Chilean Offer may remain open. If the Chilean Offer closes before the U.S. Offer, will
Chilean holders who tender be paid before tendering U.S. holders? Please advise in your response letter. If yes, analyze how this is consistent
with the requirements of Rule 14d-1(d)(2)(ii).

    SHEARMAN.COM

    Shearman & Sterling LLP is a limited liability partnership organized in the United States under the laws of the state of Delaware, which laws limit the personal liability of partners.

Response: Purchaser intends to conduct the U.S. Offer
and the Chilean Offer concurrently and intends for the U.S. Offer and the Chilean Offer to expire on the same day. Due to differing regulations
under Chilean and U.S. regulatory schemes, it is possible (although not anticipated) that the Chilean Offer could expire on a date that
is prior to the Expiration Date. If this occurs, there is a possibility that payment for Common Shares tendered into the Chilean Offer
could be made before payment for Shares tendered into the U.S. Offer.

If the Expiration Date occurs after the expiration date of
the Chilean Offer and at least two business days prior to the Settlement Date, Purchaser undertakes to make payment for Shares tendered
into the U.S. Offer on the Settlement Date. If the Expiration Date occurs one business day prior to the Settlement Date or later, Purchaser
will make payment for Shares tendered into the U.S. Offer no later than promptly after the expiration of the U.S. Offer.

We respectfully submit that the terms of the U.S. Offer are
at least as favorable as those of the Chilean Offer notwithstanding a possible delay in the settlement of the U.S. Offer because an extension
of the U.S. Offer would afford holders tendering into the U.S. Offer additional time (not available to holders tendering into the Chilean
Offer) to evaluate and respond to any material change to the terms of the U.S. Offer.

In response to the Staff’s comment, we have revised
the Schedule TO, in the relevant portions of the U.S. Offer to Purchase and all other ancillary exhibits, to include the following disclosure:

“If the Expiration Date occurs after
the expiration date of the Chilean Offer and at least two business days prior to the Settlement Date, Purchaser undertakes to make payment
for Shares tendered into the U.S. Offer on the Settlement Date. If the Expiration Date occurs one business day prior to the Settlement
Date or later, Purchaser will make payment for Shares tendered into the U.S. Offer no later than promptly after the Expiration Date. In
the event that the U.S. Offer expires one business day prior to the Settlement Date or later, the U.S. Offer Price paid to holders of
Shares will be converted into U.S. dollars based on the Observed Exchange Rate published by the Central Bank of Chile in the Official
Gazette of Chile on the Expiration Date.”

What are the differences between the U.S. Offer and the Chilean
Offer?, page v

 2. The disclosure here and on page 10 of the offer materials describes potential differences
between the withdrawal rights provided in the U.S. and Chilean Offers. In your response letter, please explain whether a scenario could
arise where withdrawal rights in the Chilean Offer could extend beyond those provided in the U.S. Offer. If so, explain how this would
satisfy your Tier II obligation to make the U.S. Offer on terms at least as favorable as the Chilean Offer.

Response: In accordance with article 211 of the Chilean
Securities Act, tenders of Common Shares into the Chilean Offer may be withdrawn at any time prior to the expiration of the Chilean Offer.
Tenders of Common Shares and ADSs made pursuant to the U.S. Offer may be withdrawn at any time prior to the Expiration Date, which is
intended by Purchaser to coincide with the expiration date of the Chilean Offer.

      Page 2 of 14

In accordance with article 212 of the Chilean Securities Act,
on the third Chilean calendar day following the expiration of the Chilean Offer, Purchaser must publish the notice of acceptance of the
Chilean Offer. If Purchaser fails to comply with such obligation (this is not anticipated), tenders of Common Shares into the Chilean
Offer may also be withdrawn after expiration of the Chilean Offer. Purchaser intends to comply with its obligations under the Chilean
Securities Act and publish the notice of acceptance of the Chilean Offer on the third Chilean calendar day following the expiration of
the Chilean Offer. Purchaser does not envisage a scenario where the withdrawal rights in the Chilean Offer would extend beyond those provided
in the U.S. Offer. In the event that withdrawal rights in the Chilean Offer are reinstated for a period after the expiration of the Chilean
Offer (this is not anticipated), Purchaser will clarify in the offer materials that tenders of Shares into the U.S. Offer may be withdrawn
during the same period.

In response to the Staff’s comment, we have revised
the Schedule TO, in the relevant portions of the U.S. Offer to Purchase and all other ancillary exhibits, to include the following disclosure:

“If withdrawal rights in the Chilean
Offer are reinstated for a period after the expiration of the Chilean Offer, we will announce such reinstatement by giving notice to The
Bank of New York Mellon, followed as promptly as practicable by a public announcement thereof (which, in any event, will be made no later
than 9:00 a.m., New York City time), on the first business day on which such withdrawal rights are reinstated. During any period after
the expiration of the Chilean Offer in which the withdrawal rights applicable to tenders of Common Shares into the Chilean Offer are reinstated,
tenders of Shares into the U.S. Offer may be withdrawn in accordance with the terms of this U.S. Offer to Purchase.”

Purpose of and Reasons for the U.S. Offer; Plans for the Company
After the U.S. Offer, page 6

 3. We note your disclosure that “IUH and Purchaser are making the Offers … to increase
the weight of markets with structural growth in IUH’s business portfolio.” Revise to clarify how and why acquiring the Common
Shares would increase the weight of markets with structural growth in IUH’s business portfolio. See Instruction 1 and Instruction
2 to Item 1013 of Regulation M-A.

Response: In response to the Staff’s comment,
the relevant disclosure has been amended as part of Amendment No. 1 as follows:

“IUH and Purchaser are making the
Offers to acquire up to all of the outstanding Common Shares (including Common Shares represented by ADSs) not owned directly or indirectly
by IUH and/or its affiliates, consistent with IUH’s aim to deploy more capital in Chile and to continue to increase the
weight of markets with structural growth in IUH’s business portfolio within Chile. IUH and Purchaser consider Chile
a core market for their activities in Latin America and are confident in its long-term fundamentals and economic growth potential. IUH
and Purchaser see attractive growth potential within the Chilean market and believe that increasing their percentage ownership of the
Company is a desirable means of advancing IUH’s aim of increasing its business investment in Chile.”

      Page 3 of 14

 4. Item 1013(d) of Regulation M-A requires a reasonably detailed discussion of the benefits and
detriments of the transaction to the subject company, its affiliates and unaffiliated security holders, and the benefits and detriments
must be quantified to the extent practicable. Please revise to include this disclosure. See Instruction 1 and Instruction 2 to Item 1013
of Regulation M-A.

Response: In response to the Staff’s comment,
Amendment No. 1 amends the U.S. Offer to Purchase to add the following disclosure as a new subsection of the section entitled “Special
Factors — Section 4. Effects of the U.S. Offer”:

“Primary Benefits
and Detriments of the Offers

The
following discussion of the benefits and detriments of the Offers is not intended to be exhaustive and includes only the material factors
considered by IUH and Purchaser. In view of the variety of factors considered in connection with their evaluation of the transaction,
IUH and Purchaser did not find it practicable to, and did not, quantify or otherwise assign relative weights to the specific factors considered
in reaching their determination.

The
primary benefits of the Offers to the Company’s Unaffiliated Shareholders include the following:

 (i) The opportunity to receive 8,500 Chilean pesos per Common Share, which represents
a premium of approximately 15.44% over the closing price, adjusted per dividends, of Ch$7,363.52 per Common Share (after giving effect
to the Reverse Stock Split) on the Santiago Stock Exchange on March 2, 2023 (the last trading day on the Santiago Stock Exchange prior
to the first public announcement of the Offers) and 2,833.33 Chilean pesos per ADS which represents a premium of approximately 9.99% over
the closing price, adjusted per dividends considering the Observed Exchange Rate published on April 20, 2023, of U.S.$3.16 per ADS on
the NYSE on March 2, 2023 (the last trading day on the NYSE prior to the first public announcement of the Offers);

 (ii) The Offers provide the Company’s Unaffiliated Shareholders with certainty
of value and immediate liquidity by enabling them to sell all or a portion of their Common Shares and/or ADSs for the U.S. Offer Price,
without incurring brokerage costs and other costs typically associated with open market sales; and

      Page 4 of 14

 (iii) Upon consummation of the Offers, holders of Common Shares and ADSs that are
purchased pursuant to the Offers will not bear the risk of losses that could be generated by the Company’s operations or the risk
of a decline in the value of the Company after completion of the Offers.

The
primary detriments of the Offers to the Company’s Unaffiliated Shareholders include the following:

 (i) Upon consummation of the Offers, holders of Common Shares and ADSs that are
purchased pursuant to the Offers will not have the opportunity to participate in the future earnings, profits and growth of the Company
and will not have any right to vote on the Company’s corporate matters;

 (ii) The purchase of Shares pursuant to the Offers will reduce the number of Shares
that might otherwise trade publicly and could reduce the number of holders of Shares, which could adversely affect the liquidity and market
value of the remaining Shares held by the public;

 (iii) The receipt of cash in exchange for Shares will be a taxable transaction for
U.S. federal income tax purposes. If holders properly tender Shares and accept payment pursuant to this U.S. Offer to Purchase, such holders
will generally recognize taxable gain or loss equal to the difference, if any, between the amount realized on the exchange and such holders’
adjusted tax basis in the tendered Shares; and

 (iv) The purchase of ADSs pursuant to the U.S. Offer may cause the failure of the Company to meet certain criteria for listing on the
NYSE, which could cause the ADSs to be involuntarily de-listed, further adversely affecting liquidity and market value of the remaining
ADSs held by the public.

The
primary benefit of the Offers to IUH and Purchaser include the following:

 (i) IUH and Purchaser will have a greater benefit from any income generated by the
Company’s operations and any increase in the value of the Company following the Offers.

The
primary detriment of the Offers to IUH and Purchaser include the following:

 (i) IUH and Purchaser will bear a greater portion of the risk of any losses generated
by the Company’s operations and any decrease in the value of the Company after completion of the Offers.

The
primary detriment of the Offers to the Company and its Affiliates include the following:

      Page 5 of 14

 (i) The purchase of ADSs pursuant to the U.S.Offer may cause the failure of
                                                                                                                            the Company to meet certain criteria for listing on the NYSE, which could cause the ADSs to be involuntarily de-listed, further
                                                                                                                            adversely affecting liquidity and market value of the remaining ADSs held by the public.”

 5. We note your disclosure that “by extending the Offers at this time, IUH and Purchaser
believe that they are offering shareholders a fair price...” Please disclose IUH and Purchaser’s reasons for undertaking the
transaction at this time. Refer to Item 1013(c) of Regulation M-A.

Response: IUH and Purchaser’s use of the phrase
“by extending the Offers at this time” was intended to convey IUH and Purchaser’s belief that the price offered to Unaffiliated
Shareholders is fair in light of the factors referenced in the preceding sentences of the disclosure. In response to the Staff’s
comment, Amendment No. 1 amends the U.S. Offer to Purchase to add the following paragraph to the section entitled “Special Factors
— Section 2. Purpose of and Reasons for the U.S. Offer; Plans for the Company After the U.S. Offer”:

“As discussed in “Special
Factors — 1. Background of the Offers,” as part of the regular review of IUH’s businesses, IUH’s management
reviews its long-term strategic goals and potential ways to address strategic imperatives and industry developments, which includes
its equity participation in investees such as the Company. Since April 2016, when the merger that resulted in the creation of the
Company (as the surviving entity) was consummated, IUH (through its affiliates) has been the controlling shareholder of the Company
and has gradually overtime increased its equity ownership of the Company as a result of contractual obligations (including the
exercise of put options) under then existing agreements (including a shareholder agreement) with Corp Group and certain of its
affiliates. Corp Group and certain of its affiliates ceased to be a shareholder of the Company as a res