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    Eversheds Sutherland (US) LLP

700 Sixth Street, NW, Suite 700

Washington, DC 20001-3980

D: +1 202.383.0176

F: +1 202.637.3593

stevenboehm@eversheds-sutherland.com

March 21, 2019

VIA EDGAR

Megan Miller

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: Oxford Square Capital Corp.

Pre-Effective Amendment No. 1 to Registration Statement
on Form N-2, Filed

March 7, 2019

File No. 333-229337

Dear Ms. Miller:

On behalf of Oxford
Square Capital Corp. (the “Company”), set forth below are the Company’s responses to the oral comments
provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) to the Company on March 15, 2019 with respect to the Company’s pre-effective
amendment no. 1 to registration statement on Form N-2 (File No. 333-229337) filed with the Commission on March 7, 2019 (the “Registration
Statement”) and the prospectus included therein (the “Prospectus”). The Staff’s comments
are set forth below in italics followed by the Company’s responses.

1.       On
page 62 of the Prospectus, we note that you include disclosure on “Bilateral Investments (Including Equity).” Please
explain if the Company currently holds such investments.

Response: The Company acknowledges
the Staff’s comment and hereby supplementally advises the Staff that the Company did not hold any bilateral investments (which
are investments directly negotiated between the Company and a portfolio company) as of December 31, 2018. However, the Company
notes that it has previously held, and may in the future hold, bilateral investments and, therefore, the Company has included in
the Prospectus disclosure regarding the Company’s valuation procedures for bilateral investments.

Eversheds Sutherland (US) LLP is part of a global legal practice,
operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure
and a list of offices, please visit www.eversheds-sutherland.com.

2.       Please
provide on a supplemental basis the calculations for the disclosure in the Senior Securities table relating to December 31, 2018.

Response: The Company acknowledges
the Staff’s comment and has provided the requested calculations on a supplemental basis.

3.       On
page 11 of the Prospectus in the “Fees and Expenses” table we note the Company’s disclosure for the interest
payments on borrowed funds. Please provide the calculations to support the percentage disclosed on a supplemental basis.

Response: The Company acknowledges
the Staff’s comment and has provided the requested calculations on a supplemental basis.

4.       Please
explain the difference between the actual results presented in the “Selected Financial and Other Data” section in the
Prospectus and the amounts presented in the “Fees and Expenses” table of the Prospectus.

Response: The Company acknowledges
the Staff’s comment and supplementally advises the Staff that certain percentages disclosed in the “Fees and Expenses”
table are based on estimates and assumptions as disclosed in the related footnote. The percentages disclosed in the “Selected
Financial and Other Data” section of the Prospectus are based on historical amounts and actual results for the periods presented.
In order to make it clear that the Company uses estimates in the “Fees and Expenses” table, in the introduction to
the table the Company discloses “We caution you that some of the percentages indicated in the table below are estimates and
may vary.”

5.       On
page F-49, it appears distributions are changing from quarterly distributions in the amount of $0.20 per share to monthly distributions
in the amount of $0.067. Please explain if this change is due to a change in anticipated leverage and if it will change the frequency
with which the Company’s net asset value (“NAV”) will be determined.

Response: The Company acknowledges
the Staff’s comment and supplementally advises the Staff that the change in the frequency of distributions is not the result
of any anticipated change in leverage and will not impact the frequency with which the Company’s NAV will be determined.
The Company advises the Staff that the decision by the Company’s Board of Directors to switch to a monthly distribution was
based on the preference of the Company’s stockholders to receive distributions more frequently and is consistent with recent
market trends.

6.       Please
explain how often the Company measures its compliance with Section 55 of the Investment Company Act of 1940, as amended (the “1940
Act”) since NAV is determined quarterly. The Staff notes that as of December 31, 2018, the Company discloses that 68% of
its total assets were “qualifying assets.” Does this mean that the Company cannot purchase assets which are not “qualifying
assets” during the first quarter of 2019?

Response: The Company acknowledges
the Staff’s comment and hereby supplementally advises the Staff that the Company measures its compliance with Section 55
of the 1940 Act, as required by such section, each time the Company makes an investment in a portfolio company. The Company respectfully
advises the Staff that, although “qualifying assets” constituted 68% of the Company’s total assets as of December
31, 2018, since compliance with Section 55 of the 1940 Act is measured at the time of each new investment it is possible that the
Company could still purchase assets which are not “qualifying assets” during the first quarter of 2019 if it first
acquires “qualifying assets” such that at the time of investing in a “non-qualifying asset” the Company
has at least 70% of “qualifying assets” in its portfolio. The Company is able to purchase assets which are not “qualifying
assets” because Section 55 of the 1940 Act requires the Company to hold 70% of “qualifying assets” at the time
any non-qualifying asset is purchased as opposed to the end of any specific fiscal period.

7.       Please
explain the difference between distributions declared per share as disclosed in the Selected Financial and Other Data table on
page 13 of the Prospectus and page F-49, on the one hand, and the amount shown in the financial highlights on page F-47, on the
other hand. We note that on page 13 of the Prospectus and page F-49, the Company discloses distributions declared per share in
the amount of $0.80 for December 31, 2018 whereas page F-47 discloses $0.79 for the same period.

Response: The Company acknowledges
the Staff’s comment and supplementally advises the Staff that the distributions per share amounts which are reflected in
the “Selected Financial and Other Data” section of the Prospectus and in “Note 11. Distributions” to the
Company’s consolidated financial statements are based on the per share amounts that were declared by the Company’s
board of directors for each period presented. On the other hand, the distributions per share amounts which are reflected in “Note
10. Financial Highlights” to the Company’s consolidated financial statements are based on the per share amounts calculated
using the weighted average shares outstanding for the respective period (i.e. there were 49,662,157 weighted average shares outstanding
for the year ended December 31, 2018). Due to the Company’s share repurchase program which was executed during the year ended
December 31, 2018, the distributions for the year ended December 31, 2018 based on the weighted average shares outstanding during
that year was $0.01 per share less than the actual per share distributions declared by the Company’s board of directors.

*       *       *

Please
do not hesitate to call me at (202) 383-0176, or Vlad M. Bulkin at (202) 383-0815, if you have any questions or require any additional
information.

    Sincerely,

    /s/ Steven B. Boehm

    Steven
B. Boehm

 cc: Jonathan H. Cohen, Chief Executive Officer, Oxford Square
Capital Corp.

Bruce L. Rubin, Chief Financial Officer,
Oxford Square Capital Corp.

Vlad M. Bulkin, Esq., Eversheds Sutherland
(US) LLP