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   Anavex Life Sciences Corp.: Correspondence - Filed by newsfilecorp.com

ANAVEX LIFE SCIENCES CORP
27 Marathonos Ave.
15351 Athens,
Greece
30 210 603 4026

March 26, 2010

BY FAX AND EDGAR

United States
Securities and Exchange Commission
Mail Stop #4720
Washington DC
20549

    Attention:
    Jim B. Rosenberg

    Senior Assistant Chief Accountant

Dear Sirs/Mesdames:

    Re:
    Anavex Life Sciences Corp. (the
      “Company”)

    Form 10-K for the Fiscal Year Ended
      September 30, 2009

    File Number: 000-51652

Thank you for your letter of March 12, 2010 regarding the
annual report noted above. The Company provide here written responses to your
comments. Our responses are numbered in a manner that corresponds with your
comments as set out in your letter.

Item 2. Properties, page 29

    1.

      As at September 30, 2009, the Company was continuing to
      pay Eurogenet Labs an amount of $70,000 per month (the amount has recently
      increased) by way of a lease for the premises in which our research and
      development activities are being performed. This lease expense has been
      included with research and development expenses in the financial
      statements for each of the years ended September 30, 2009 and 2008. We
      previously had a lease agreement with a CASAD, a Swiss company for the
      rent of premises in Switzerland. This lease ended in July, 2008 and it was
      not renewed. The agreement with CASAD was for office space in respect of
      the Company’s administration; the amount of $75,000 reflected in the
      Statement of Operations for the year ended September 30, 2008 was in
      respect of this lease. At the time the CASAD lease terminated, the
      Company’s administration was moved to British Columbia and the Company has
      not been charged rent for its administration since that
  time.

Consolidated Financial Statements

Report of the Independent Registered Accounting Firm

    2.

      The Company’s President, who also holds the title of
      Chief Financial Officer, is resident in British Columbia. The President is
      responsible for the administration of the Company. The majority of the
      Company’s assets, primarily cash, are located in British
  Columbia.

- 2 -

The accounting records of the Company
are maintained in British Columbia and the majority of the audit work was
performed in British Columbia. The Company’s auditors performed their audit in
British Columbia and there were no other auditors relied upon.

BDO Canada LLP is registered with the
PCAOB. We believe that our connection to Canada and our status as a reporting
issuer to the British Columbia Securities Commission make the selection of and
auditor that is registered with both PCAOB and the Canadian Public
Accountability Board (“CPAB”) appropriate. It is practical and cost effective
for us to engage an auditor who is registered with both PCAOB and CPAB and who
is located in Canada. We have no knowledge of or relationship with an auditor
who is registered with both entities and who is located in the U.S.

The majority of our tangible assets and
liabilities are located in British Columbia including maintenance of bank
accounts, which are with Canadian financial institutions.

Our company is a reporting issuer with
the British Columbia Securities Commission due to its connection with British
Columbia, Canada. Therefore, we believe it is reasonable to have an auditor
located in Canada and in the best interests of our company to have an auditor
registered and in good standing with the Canadian Public Accountability Board.
BDO Dunwoody is such a firm.

In 2009, our audit was performed
entirely in Vancouver, British Columbia by a engagement team based in Vancouver.
We do not expect this to change for 2010. The audit partner in Vancouver was and
will continue to be responsible for PCAOB auditing standard compliance.

The “filing reviewer” procedures
outlined in Section 1000.08n of the PCAOB Interim Quality Control Standards was
and will continue to be applied. BDO (in the United States) will provide a
filing reviewer.

BDO Canada LLP currently performs the
audits of 36 SEC registrants (including dual listed clients). The
Vancouver-based engagement team uses BDO’s PCAOB GAAS/US GAAP checklists in the
audit. The audit partner responsible for the engagement in Vancouver, together
with the manager and certain staff attend BDO sponsored education programs,
which cover US GAAP, PCAOB audit standards, independence and SEC rules and
regulations.

Foreign Currency Translation

    3.

      The Company’s functional currency is the US dollar given
      that all of the Company’s financing is done in the US dollar as well as
      the majority of its expenses are incurred in US currency. In future
      filings, the disclosure will be revised to identify the functional
      currency. The Company does hold small, insignificant balances of Canadian
      dollars and Euros. As such, the effect of exchange rate changes on cash is
      immaterial to disclose as a separate part of the reconciliation of the
      change in cash and cash equivalents.

- 3 -

The Company acknowledges 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 defence in any proceeding
  initiated by the Commission or any person under the federal securities laws of
  the United States.

We look forward to any further comments you may have with
respect to our responses.

Yours truly

ANAVEX LIFE SCIENCES
CORP

 Per: “Harvey Lalach”

  Harvey Lalach,

  President and Chief
  Executive Officer