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January 30, 2023
Brent Bowman
Chief Financial Officer
Veeva Systems Inc.
4280 Hacienda Drive
Pleasanton, CA 94588
Re:Veeva Systems Inc.
Form 10-K for the Fiscal Year Ended January 31, 2022
Filed March 30, 2022
Form 10-Q for the Quarter Ended October 31, 2022
Filed December 7, 2022
File No. 001-36121
Dear Brent Bowman:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Quarter Ended October 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 32
1.We note that your Non-GAAP liquidity measure, Net cash provided by operating
activities on a non-GAAP basis, includes an adjustment for "Impact of tax legislation."
Considering that this adjustment appears to relate to required higher estimated tax
payments resulting from the change in the treatment of research-and-development costs
pursuant to the TCJA ("direct cash payments"), please remove this adjustment in future
filings. Refer to Item 10(e)(1)(ii)(A) of Regulation S-K.

 FirstName LastNameBrent Bowman
 Comapany NameVeeva Systems Inc.
 January 30, 2023 Page 2
 FirstName LastName
Brent Bowman
Veeva Systems Inc.
January 30, 2023
Page 2

Cash Flows from Operating Activities, page 34
2.We note that your cash flows from operating activities for the nine months ended
October 31, 2022 were reduced as a result of certain provisions in the Tax Cuts and Jobs
Act of 2017. Additionally, you expected cash flows from operating activities to be
substantially less in the fourth quarter.  In your Annual Report, please discuss any material
tax-related cash requirements arising from commitments or uncertainties in connection
with the Tax Cuts and Jobs Act that will result in or that are reasonably likely to result in
your liquidity increasing or decreasing in any material way, including the relevant time
period for such cash requirements as applicable. Refer to Item 303(b)(1)(i) of Regulation
S-K.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Claire DeLabar, Senior Staff Accountant at (202) 551-3349 or Kathryn
Jacobson, Senior Staff Accountant at (202) 551-3365 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology