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              Seward & Kissel llp

              ONE BATTERY PARK PLAZA

              NEW YORK, NEW YORK  10004

              TELEPHONE:  (212)  574-1200

              FACSIMILE:  (212) 480-8421

              WWW.SEWKIS.COM

              901 K STREET, NW

              WASHINGTON, D.C. 20001

              TELEPHONE:  (202) 737-8833

              FACSIMILE:  (202) 737-5184

      January 21, 2020

      U.S. Securities and Exchange Commission

      Division of Corporation Finance

      100 F Street, N.E.

      Washington, D.C. 20549

              Attention:

              Brian McAllister

              Raj Rajan

               Re:

              Euronav NV

              Form 20-F for the fiscal year ended December 31, 2018

              Filed on April 30, 2019

              File No. 001-36810

      Dear Mr. McAllister,

      We refer to the annual report on Form 20-F for the fiscal year ended December 31, 2018 filed by Euronav NV (the “Company”) with the Securities and
        Exchange Commission (the “Commission”) on April 30, 2019 (the “Annual Report”).  By letter dated December 26, 2019 (the “Comment Letter”), the staff of the Commission (the “Staff”) provided the Company with its comments to the Annual Report.  The
        Company’s responses to the Comment Letter are set forth below with each Company response prefaced by the exact text of the Staff’s corresponding comment in bold text.

    Form 20-F for the fiscal year ended December 31, 2018

    Item 5. Operating and Financial Review Prospects

    Critical Accounting Policies

    Calculation of Recoverable Amount, page 85

              1.

              We note in determining the recoverable amount of your tankers, you make several assumptions about your future performance and develop estimates of future cash flows.  We note that in the
                past you used a fixed cut of 10 years to define a shipping cycle and 10 year historical average spot freight rates as forecast charter rates.  However, in 2018, you define a shipping cycle to include the past 20 years and use forecast
                charter rates based on a weighted average of the past and ongoing current shipping cycle.  You state that when using 10 year historical charter rates in your impairment analysis, it indicated that an impairment is required for of the tanker
                fleet in the amount of $47.9 million in 2018.

    Please address the following:

    •  Please explain in detail the
        new methodology, the basis for the new forecasted cycle and related assumptions used in 2018, why it is preferable and the underlying reasons for the change.

    •  Please explain how the recoverable amount determined under the new methodology using a longer shipping cycle is more reliable and
      represents management’s best estimate of the range of economic conditions that will exist over the remaining useful life of the tanker fleet.

    •  Considering
          significant volatility and declines in charter rates in recent years, tell us how using the last 20 years for a shipping cycle provides management the ability to give more weight to recent and current market experience than a 10 year period.

      SEC Question 1: Explain in detail the new methodology, the basis for the new forecasted cycle and related assumptions used in 2018, why it is preferable and the underlying reasons for the change.

    Underlying reasons for the change and preferability

    The Company’s policy since 2010 was to use the 10-year average historical spot freight rates in its impairment model, while at the same time disclosing the potential impact
      of the alternative using either the 5 and 1-year rates.

    During Q2 2018, the Company determined that the existing impairment assessment model had become disconnected from observable trends and no longer met the requirements of IAS
      36, so it was considered preferable to introduce a revised model.

    Since the Company’s listing on NYSE and becoming subject to the U.S. Securities Exchange Act of 1934 reporting and registration requirements, the Company has disclosed the
      following in its annual report on form 20-F:

            Potential impairment based on:

            10-year average

            5-year average

            1-year average

            Capital gain/(loss) on disposals

            2014

            -

            952.0M

            103.7M

            5.7M

            2015

            -

            123.3M

            -

            5.3M

            2016

            -

            -

            -

            50.4M

            2017

            -

            5.7M

            427.3M

            15.5M

            2018

            47.9M

            -

            92.7M

            15.9M

    IAS 36.9 defines an impairment loss as the amount by which the carrying amount of an asset or a cash-generating unit (CGU) exceeds its recoverable amount.  The recoverable
      amount of an asset is defined as the higher of its fair value less cost of disposal and its value in use. Individual vessels are deemed to constitute a CGU unless they are operated in a net revenue sharing pool.

    The Company also presents in the table above its actual disposal experience as a potential indicator as to whether our impairment assessment model was reliable. The actual
      disposal experience indicates that the Company has been able to sell its older tonnage at a price close to or above its carrying value.

    The Company advises the Staff that it has always attempted to establish its impairment methodology in the most objective manner and to use assumptions that are objective and,
      to the greatest extent possible, observable in the market or provided by independent third parties, which was the case again in 2018.

    Under IAS 36.33, in measuring value in use, an entity shall base cash flow projections on reasonable and supportable assumptions that represent the Company's best estimate of
      the range of economic conditions that will exist over the remaining useful life of the asset. Greater weight shall be given to external evidence. The principal input to the impairment methodologies, both new and old, is the freight rates that are
      observable in the market.

    Spot freight rates have historically been driven by the demand and supply of oil, the ton miles required to transport that oil, the vessel supply and geopolitical events such
      as sanctions and the threat of war. This leads to volatility, that impacts the historic rates in a manner that might not reflect the true expectations of the Company’s ability to recover the value of its vessels over a 20-year useful life with the
      use of a simple average rate.

    The Company has observed over time that the reliability of 10-, 5- and 1-year rate is dependent on whether particular years with special events (a high performing or
      distressed year) come into or drop out of the calculation. This impact implies that the average rate at a reporting date can benefit from or be penalized by the addition or subtraction of a particular year independently from market expectations of
      the performance of a vessel over its remaining useful life.

    When determining the recoverable amount, the Company reviews its methodology and parameters and evaluates whether those are still appropriate given the market, and the
      Company’s view of the expected evolution of the rates over the remaining useful life of the vessels.

    Developing an estimate for future TCE1 over the remaining life of each vessel is complex considering the volatility in the shipping market. However history has
      shown that rates evolve on a cyclical basis over the useful life of a vessel, and after bad years, peaks or good rates follow. The Company has therefore resorted to a measure generally retained in the shipping industry which is to look at historical
      TCEs as a basis to estimate the recoverable amount.

    When the Company first designed its impairment assessment model in 2010, taking into account the life of the vessels and the prevailing macroeconomics trends, the Company
      used historical TCEs as an indication of future TCEs. The Company sought to add robustness to this measure by electing (1) an external data source provider for historical TCEs – namely Clarksons2 (the largest international ship broker) and
      (2) a 10-year range. Considering a 10-year average for a shipping cycle seemed at that time to be a generally agreed duration of a shipping cycle in the industry, capturing the peaks and troughs in the shipping market.

    During 2018, the Company noticed an increase in the fair market values of the vessels throughout the year. Over 2018, the fair market value of the Company’s vessels increased
      by 7.6% as estimated by reputable third party brokers such as Clarksons and Braemar. In addition, several analysts forecasted the bottoming out of the rate crisis, as evidenced by a strong market in Q4 2018 and early 2019 with TCEs around or above
      USD 35,000/day for a VLCC, well above break even for impairment purposes. This positive outlook contrasted sharply with the drop in the 10-year average TCE rate over 2018, caused by the exceptional year 2008 dropping out of the average. The graph
      below shows the valuation of the Company’s fleet over the course of 2018 according to vesselvalues.com compared to the calculated 10 year average daily TCE based on the daily TCE rates as provided by Clarksons.

      1  Time Charter Equivalent is a standard shipping industry performance measure used primarily to compare period-to-period changes in a shipping company's
        performance despite changes in the mix of charter types under which the vessels may be employed between the periods. The  standard method to compute TCE is to divide voyage revenues ( net of expenses) by available days for the relevant time period.
        Expenses primarily consist of port, canal and fuel costs.

      2  Clarksons is an independent internationally recognized provider of integrated shipping services and shipping broker including historical Time Charter
        Equivalent rates (TCE). Clarksons TCE rates have been proven to be consistent and a good proxy – https://www.clarksons.com

    Applying the previous impairment model would have resulted in an impairment loss of $47.9 million as of December 31, 2018. When it performed its impairment
      assessment in February/ March 2019, the Company expected as part of the evolution of freight rates an increase in the TCE rates during Q1 and Q2 2019, based  on what was observable at the time and as a continuation of the higher rates observed in Q4
      2018, which would have led to a partial reversal of that loss in Q1 2019 as IAS 36.110 requires the Company to assess at each reporting period whether there is an indication that an impairment loss recognized in prior periods for an asset other than
      goodwill no longer exist or may have been decreased.

    As of December 2018, the Company in accordance with IAS 36.111 considered the following indications that could lead to the conclusion that an impairment
      loss had decreased or no longer existed:

              o

              External information:

              ◾

              the Company noted that TCE rates were increasing significantly from Q4 2018 and market expectations at that time was that the TCE rates were expected to further increase significantly during 2019 to an
                expected new peak in 2020; and

              ◾

              This was reflected in the increase in the fair value of the vessels as provided by Clarksons and Braemar (see chart above).

              o

              External information: while in previous periods the 10-year average TCE rates included at least two complete cycles, the 2018 10-year average TCE rate only included one complete cycle with
                longer periods of low TCE rates (before and after the peak in 2015). Based on its experience, the Company has observed that over its life, a vessel goes through multiple cycles and as the Company has historically generated gains (on
                average) on the sales of its older vessels, the Company concluded that considering only one cycle, albeit the most recently completed one, did not provide an appropriate reflection of either its historical experience or of the long-term
                expectations of the market at that time. The Company refers the Staff to the further analysis below.

              o

              Internal information: certain vessels had contracted TCE rates for voyages in Q1 and Q2 2019 which were higher than the average TCE rates calculated using the impairment model using a 10-year average showing
                that freight rates had bottomed out while the 10-year average TCE continued to decline.

    IAS 36.114 requires the Company to reverse the impairment loss recognized in prior periods for an asset when there has been a change in the estimates to
      determine the recoverable amount and the carrying value of the vessels shall be increased to their recoverable amount. The change in estimate relevant for IAS 36.114 is the significant expected increase in TCE rates, which aligned with the observable
      increase in vessel fair value.

    The foregoing points led management to conclude as of December 31, 2018 that the impairment assessment model using the 10-year average historical TCE
      rates might not be an appropriate basis anymore to estimate the future TCE rates and that the previous impairment assessment model was no longer compliant with the IAS 36.33 requirement that the cash flows should represent the Company’s best estimate
      of the range of economic conditions that will exist over the remaining useful life of the asset.

    Basis for the 20-year forecast cycle and related TCE assumption

    The following is a detailed explanation of how the Company conducted its analysis:

    The above chart shows the annual average achieved TCE day rates as published by Clarksons, and eliminates the seasonality within a year. It shows that the rates are very
      volatile with highs of almost USD 100,000/day to lows below USD 20,000/day.

    In order to determine the duration of a cycle, the Company took the position that a cycle started with a peak and ended the year before the next expected peak, so as to avoid
      doubling counting peaks.3 As a result, the start of a cycle is defined in the following years: 2000, 2004, 2008 and 2015. The Company identified also a cycle from a low to the next low, but this is less robust as several lows in one cycle
      or a longer period of low rates can be observed, which are not in line with our expectations of the financial performance of a vessel over its useful life. However, this information was considered in the sensitivity analyses which are further
      detailed below.

      This analysis results in 4 observable cycles since 2000, extending from a period of 4 years (2 cycles) to a period of 7 years (1 cycle). The longer period of the third cycle, between 2008 and
        2014 was caused by the combined effect of the 2008 financial crisis, credit constraints and the delivery of new builds at the beginning of the decade. This observable cyclicality demonstrates why the 10 year average over time became a less accurate
        reflection of shipping cycles: in previous years, a 10-year average covered two peaks whereas the last 10 years as of December 31, 2018 would only consider the peak in 2015 and the depressed years before and after that peak. In particular, at the
        end of 2018 the Company strongly believed that a surge in rates would take place in the years to come, with both temporary and long terms factors being the cause. One “permanent” factor was IMO 2020, which would affec