SecProbe.io

CORRESP
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September 14, 2022

VIA EDGAR

Ms. Ashley Vroman-Lee

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re:      Response to Comments
on the Preliminary Schedule 14A filings filed on August 19, 2022 (each a “Proxy Statement” and, collectively, the “Proxy
Statements”) for abrdn Income Credit Strategies Fund (“ACP”) (SEC File No. 811-22485),
abrdn Global Dynamic Dividend Fund (“AGD”) (SEC File No. 811-21901) and abrdn Global Infrastructure Income Fund (“ASGI”)
(SEC File No. 811-23490) (each a “Fund” and, collectively, the “Funds”)

Ms. Vroman-Lee:

This letter responds to comments provided by telephone
on August 25, 2022, with respect to the Proxy Statements. On behalf of the Funds, your comments and our responses thereto are provided
below. All defined terms in this letter have the same meaning as the Proxy Statements, except as defined herein.

Comment applicable to abrdn Global Infrastructure
Income Fund only

Comment 1: Please move the following
disclosure from the response to the question “Why is a shareholder meeting being held?”

Additionally, to promote continuity
in the oversight of the Combined Fund, at the next regularly scheduled meeting of the Fund’s Nominating and Corporate Governance
Committee (the “Committee”), the Committee will consider recommending the nomination of Gordon A. Baird, Thomas W. Hunersen
and Chris LaVictorie Mahai, each currently a member of the Board of Directors of the Acquired Fund (the “Acquired Fund Board”),
to the Board of Trustees of the Fund, subject to approval by shareholders at the next annual general meeting of the shareholders of the
Fund.

Response: The disclosure has been
moved to the response to the question “How will the Reorganization affect the Fund and its shareholders?”.

Comments applicable to each Proxy Statement

Comment 1: In response to the question
 “Why is the Reorganization being proposed?”, please delete the following.

None of the Directors, including those
who are not “interested persons” of the Acquired Fund (the “Independent Directors”) as that term is defined in
the Investment Company Act of 1940, as amended (the “1940 Act”), have any interest in the Reorganization, and the Acquired
Fund Board, including all of the Independent Directors voting separately, unanimously approved the Reorganization.

Response: The disclosure has been
deleted.

Comment 2: In response to the question
 “How will the Reorganization affect the Fund and its shareholders?”, please make clear that there is no guarantee that any
benefit will occur as a result of the Reorganization and disclose any potential negative consequences of the Reorganization.

Response: The disclosure has been
amended as follows (new text underlined):

There can be no guarantee that any anticipated
benefits will occur as a result of the Reorganization. Additionally, among other potential consequences of the Reorganization, portfolio
transitioning due to the Reorganization may result in capital gains or losses, which may have federal income tax consequences for shareholders
of the Combined Fund. Please see “Board Considerations” in the Proxy Statement for additional information.

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Comment 3: In response to the question
 “How will the Reorganization affect the Fund and its shareholders?”, please disclose the possibility of a tax impact to the
Fund and its shareholders.

Response: Please see the response
to Comment 2 above.

Comment 4: In response to the question
 “Will the Reorganization impact Fund distributions to shareholders?”, please disclose that the Combined Fund “expects
to pay” a periodic distribution rather than “would pay” a periodic distribution.

Response: The disclosure has been
revised accordingly.

Comment 5: In response to the question
 “Will there be any significant portfolio transitioning in connection with the Reorganization that impacts Fund shareholders?”,
please include the costs of portfolio transitioning and who will pay these costs.

Response: The following disclosure
has been added:

ACP:

Transaction costs (including brokerage
commissions, transaction charges and related fees) associated with such sales and purchases made by the Combined Fund after the closing
of the Reorganization will be borne by the shareholders of the Combined Fund. If the Reorganization was completed on July 18, 2022, the
transaction costs anticipated to be incurred in portfolio transitioning are estimated to be approximately $968,000 (or 26 bps of the Combined
Fund’s estimated assets as of July 18, 2022). The foregoing estimates are subject to change depending on the composition of the
portfolio holdings transferred to the Acquiring Fund at closing and market circumstances when the portfolio transitioning occurs.

AGD:

Transaction costs (including brokerage
commissions, transaction charges and related fees) associated with such sales and purchases made by the Combined Fund after the closing
of the Reorganization will be borne by the shareholders of the Combined Fund. If the Reorganization of DEX only was completed on July
18, 2022, the transaction costs anticipated to be incurred in portfolio transitioning are estimated to be approximately $294,000 (or 10
bps of the Combined Fund’s estimated NAV as of July 18, 2022). This breaks down across commissions costs of roughly $30,000, and
spread related costs for fixed income and international securities of approximately $209,000 and stamp duties/taxes of $54,000. If the
Reorganization of DDF only was completed on July 18, 2022, the transaction costs anticipated to be incurred in portfolio transitioning
are estimated to be approximately $132,000 (or 5 bps of the Combined Fund’s estimated NAV as of July 18, 2022). This breaks down
across commissions costs of roughly $21,000, and spread related costs for fixed income and international securities of approximately $84,000
and stamp duties/taxes of $27,000. If both Reorganizations were completed on July 18, 2022, the transaction costs anticipated to be incurred
in portfolio transitioning are estimated to be approximately $426,000. The foregoing estimates are subject to change depending on the
composition of the portfolio holdings transferred to the Acquiring Fund at closing and market circumstances when the portfolio transitioning
occurs.

ASGI:

Transaction costs (including brokerage
commissions, transaction charges and related fees) associated with such sales and purchases made by the Combined Fund after the closing
of the Reorganization will be borne by the shareholders of the Combined Fund. If the Reorganization was completed on July 18, 2022, the
transaction costs anticipated to be incurred in portfolio transitioning are estimated to be approximately $397,000 (or 8 bps of the Combined
Fund’s estimated NAV as of July 18, 2022). This breaks down across commission costs of roughly $83,000, spread related costs for
international securities of approximately $138,000 and stamp duties/taxes of $176,000. The foregoing estimates are subject to change depending
on the composition of the portfolio holdings transferred to the Acquiring Fund at closing and market circumstances when the portfolio
transitioning occurs.

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Comment 6: In response to the question
 “Is the Reorganization expected to be taxable to shareholders of the Fund?”, please consider disclosing whether portfolio
transitioning is likely to result is a capital gain or a capital loss and whether such gain or loss is expected to be significant.

Response: The following disclosure
has been added:

ACP:

For example,
if the Reorganization was completed on March 31, 2022, it is estimated that approximately
$13.37 million, or $0.27 per share, in capital losses would have resulted from portfolio
transitioning in the Fund following the Reorganization.

The actual tax consequences as a result
of portfolio repositioning after the closing of the Reorganization is dependent on the portfolio composition of the Acquired Fund at the
time of closing and market conditions. Any net capital gain resulting from the realignment coupled with the results of the Fund’s
normal operations during the tax year following the close of the Reorganization would be distributed to the shareholder base of the Combined
Fund post-Reorganization in connection with the annual distribution requirements under U.S. federal tax laws.

AGD:

For example, if the Reorganization of
DEX only was completed on May 31, 2022, it is estimated that approximately $5.86 million, or $0.27 per share, in capital losses would
have resulted from portfolio transitioning in the Fund following the Reorganization. If the Reorganization of DDF only was completed on
May 31, 2022, it is estimated that approximately $6.99 million, or $0.37 per share, in capital gains would have resulted from portfolio
transitioning in the Fund following the Reorganization. If both Reorganizations were completed on May 31, 2022, it is estimated that approximately
$113 million, or $0.04 per share, in capital gains would have resulted from portfolio transitioning in the Fund following the Reorganizations.
As of October 31, 2021, AGD has a capital loss carryfoward of $14,214,753 which could be used to offset the gains estimated to be generated
from the sales of securities post-merger from DDF.

The actual tax consequences as a result
of portfolio repositioning after the closing of a Reorganization is dependent on the portfolio composition of the relevant Acquired Fund
at the time of closing and market conditions. Any net capital gain resulting from the realignment coupled with the results of the Fund’s
normal operations during the tax year following the close of the Reorganization would be distributed to the shareholder base of the Combined
Fund post-Reorganization in connection with the annual distribution requirements under U.S. federal tax laws.

ASGI:

For example,
if the Reorganization was completed on May 31, 2022, it is estimated that approximately
$21.64 million, or $0.85 per share, in capital gains would have resulted from portfolio transitioning in the Fund following the Reorganization.

The actual tax consequences as a result
of portfolio repositioning after the closing of the Reorganization is dependent on the portfolio composition of the Acquired Fund at the
time of closing and market conditions. Any net capital gain resulting from the realignment coupled with the results of the Fund’s
normal operations during the tax year following the close of the Reorganization would be distributed to the shareholder base of the Combined
Fund post-Reorganization in connection with the annual distribution requirements under U.S. federal tax laws. In addition, the Fund is
covered by an exemptive order received by the Fund’s investment adviser from the U.S. Securities and Exchange Commission. The exemptive
relief allows the Fund to distribute long-term capital gains as frequently as monthly in any one taxable year. It is possible that gains
generated post-Reorganization may be used to supplement the monthly distribution payable to the Combined Fund’s shareholders.

Comment 7: Under “Proposal,”
please include disclosure regarding capital gains or losses, which may have federal income tax consequences for shareholders of the Combined
Fund.

Response: The disclosure has been
amended to include the information provided in response to Comment 6 above.

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Comments applicable to abrdn Income Credit
Strategies Fund only

Comment 1: Given that the Fund is
currently trading at a premium whereas the Acquired Fund is currently trading at a discount and that the Reorganization is taking place
at net asset value, please disclose that the market value of the Combined Fund could be adversely affected by shareholders of the Acquired
Fund selling out of the Combined Fund after the Reorganization.

Response: The following disclosure
has been added:

To the extent the Acquired Fund is trading
at a discount to its net asset value and the Fund is trading at a premium to its net asset value at the time of the Reorganization, Acquired
Fund shareholders would have the potential for an economic benefit. There can be no assurance that, after the Reorganization, common shares
of the Combined Fund will trade at, above or below net asset value. The market value of the common shares
of the Combined Fund may be less than the market value of the common shares of the Fund prior to the Reorganization.

Comment 2: Please align the expenses
of the Fund presented in the “Fees and Expenses Table” with those presented in the Financial Highlights for the six-month
period ended April 30, 2022, in the Fund’s Semi-Annual Report for the fiscal period ended April 30, 2022.

Response: There are certain differences
between the requirements for inclusion of items in the Fund’s Fees and Expenses Table and financial reporting requirements relating
to the Financial Highlights in the Fund’s Semi-Annual Report. For purposes of the Fees and Expenses Table, “dividends on preferred
shares” are required to be reflected as an expense line item; however, according to U.S. GAAP, such amounts are considered distributions
to shareholders and are therefore reflected as such under operating performance, and not as a fund expense, in the Fund’s Semi-Annual
Report. In addition, the Fund has acquired fund fees and expenses, which are required to be reflected as an expense item in the Fees and
Expenses Table, but which are not required to be included as part of the Fund’s expense ratio in its Semi-Annual Report. The Registrant
believes that these two items account for the discrepancies between the Fees and Expenses Table and the Financial Highlights presented
in the Fund’s Semi-Annual Report; as a result, the Registrant has not made any changes to the Fees and Expenses Table in response
to this comment.

Please contact the undersigned at 202-261-3360
should you have any questions regarding this matter.

    Sincerely,

    /s/
    Thomas C. Bogle

    Thomas C. Bogle

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