SecProbe.io

Mailstop 3233
        August 29, 2016

Via E -mail
Mr. Bryan K. Davis
Principal Financial Officer
Brookfield Property Partners L.P .
73 Front Street, 5th Floor
Hamilton, HM 12, Bermuda

Re:  Brookfield Property Partners L.P.
 Form 20-F for the fiscal year ended December 31, 2015
Filed March 17 , 2016
File No. 001-35505

Dear Mr. Davis :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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 20 -F for the year ended December 31, 2015

Financial statement s analysis, page 60

1. We note your disclosure of certain assumptions used in your valuation of your investment
properties and that these assumptions appear to be Level 3 unobservable inputs.  In future
periodic filing, please include a sensitivity analysis of material assumptions based on
reasonably likely changes.  Please provide us an example of your proposed disclosures.

Segment performance, page 68

2. We note your disclosure of NOI from your unconsolidated properties, which is presented
on a proportionate  basis.  In future filings, please:
a. Include a reconciliation to the most directly comparable financial measure
calculated and presented in accordance with IFRS;

Mr. Bryan K. Davis
Brookfield Property Partners L.P.
 August 29, 2016
 Page 2

 b. Include a statement disclosing the reasons why you believe this measure provides
useful informa tion to investors; and
c. Clarify what is meant by proportionate basis.
Refer to Item 10(e) of Regulation S -K.  Please provide us an example of your proposed
disclosure.  Alternatively, tell us why you believe it is unnecessary to include such
information in future filings.

Notes to the consolidated financial statements, pa ge F-10

Note 13. Other Non -Current Assets, page F -39

e) Intangible Assets, page F -40

3.  Please revise future filings to include disclosures required by paragraphs 118 and 122(a)
of IAS 38, or tell us how you determined these disclosures are not necessary.  Within
your response, please provide us an example of your proposed disclosures.

Note 38. Segment information, page F -66

c) Reportable segment measures, page F -67

4.  Please tell us how you complied with paragraph 28(b) of IFRS 8, or tell us  how you
determined it was not necessary to provide a reconciliation of company FFO to Income
before income taxes.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includ es the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequac y of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging 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 defense in any proceeding initiated by
the Commission or any person u nder the federal securities laws of the United States.

Mr. Bryan K. Davis
Brookfield Property Partners L.P.
 August 29, 2016
 Page 3

 You may contact Peter McPhun  at 202-551-3581 or me at 202-551-3295 with any
questions.

Sincerely,

 /s/ Jennifer Monick

Jennifer Monick
Assis tant Chief Accountant
Office of Real Estate and
Commodities