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United States securities and exchange commission logo
February 1, 2024
Enrique López Lecube
Chief Financial Officer
Bioceres Crop Solutions Corp.
Ocampo 210 bis, Predio CCT, Rosario
Province of Santa Fe, Argentina
Re:Bioceres Crop Solutions Corp.
Form 20-F for Fiscal Year Ended June 30, 2023
Form 6-K Filed September 11, 2023
File No. 001-38836
Dear Enrique López Lecube:
            We have reviewed your filing and have the following comment(s).
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended June 30, 2023
Item 4. Information on the Company
A. History and Development of the Company
General Overview, page 42
1.We note your presentation of Adjusted EBITDA without also presenting the most directly
comparable financial measure or measures calculated and presented in accordance with
IFRS-IASB with equal or great prominence.  Please revise your presentation to comply
with Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures.  Address this comment in
your earnings press releases for Adjusted EBITDA, Adjusted EBITDA margin and net
debt / LTM Adjusted EBITDA included as exhibits to Form 6-K in accordance with Rule
100(a) of Regulation G as interpreted by Question 102.10(a) of the Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures.

 FirstName LastNameEnrique López Lecube
 Comapany NameBioceres Crop Solutions Corp.
 February 1, 2024 Page 2
 FirstName LastNameEnrique López Lecube
Bioceres Crop Solutions Corp.
February 1, 2024
Page 2
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Results of Operations, page 73
2.Please provide a more comprehensive discussion and analysis of your operating results at
both the consolidated and segment levels, including the segment profit measure used by
the CODM, gross profit, that includes specific, material factors positively and negatively
impacting each material line item along with an analysis of those material factors.  In this
regard, refer to the expanded analysis you provide in your earnings press release included
in the 6-K filed on September 11, 2023.  As part of your analysis, provide the impact of
the Syngenta distribution and R&D agreement and the supply agreement to revenue and
also your profit measures.  For revenue, ensure you also discuss and quantify the extent to
which changes in pricing, volume and/or the introduction of new products contributed to
fluctuations at the consolidated and segment levels.  To the extent that a change in the mix
of products has impacted your profit measure, provide an explanation for what the change
entails and whether you expect the change to continue into the future.  When multiple
factors positively and/or negatively impact a line item, ensure you quantify the impact of
each factor.  Refer to Item 303(b)(2) of Regulation S-K and Section 501.12.b. of the
Financial Reporting Codification (i.e., Release 33-8350, Section III.B.) for guidance.
B. Liquidity and Capital Resources, page 77
3.We note your disclosure on page 20 that the Argentinian subsidiaries are temporarily
restricted from making payments for foreign debt.  Please provide a discussion of where
your cash and cash equivalents are held, the amount of debt held outside of Argentina and
how you are making payments on this debt.  Refer to Item 303(b)(1)(i) of Regulation S-K
and Section 501.13 of the Financial Reporting Codification (i.e., Release 33-8350, Section
IV) for guidance.
4.Please expand your analysis of operating cash flows to discuss the material factors
impacting the amount recognized to explain the material factors resulting in you
recognizing positive, near breakeven cash flows of $2.6 million for fiscal year 2023
compared to negative operating cash flows of $17.5 million for fiscal year 2022.  As part
of your analysis, address the increase in trade receivables of $56.9 million, which appears
to have increased at a higher rate than revenues.  An analysis of days sales outstanding or
other measures utilized by management to monitor the aging of your trade receivables, the
largest components of total current assets, may be useful to an investor.  Refer to Item
303(b)(1)(i) of Regulation S-K and Section 501.13 of the Financial Reporting
Codification (i.e., Release 33-8350, Section IV) for guidance.
Consolidated Statements of Comprehensive Income, page F-8
5.Please tell us what the total amount for Revenues from contracts with customers, Initial
recognition and changes in fair value of biological assets at the point of harvest, and

 FirstName LastNameEnrique López Lecube
 Comapany NameBioceres Crop Solutions Corp.
 February 1, 2024 Page 3
 FirstName LastNameEnrique López Lecube
Bioceres Crop Solutions Corp.
February 1, 2024
Page 3
changes in the net realizable value of agricultural products after harvest represents and
why you believe it is in accordance with IAS 1.85 and IAS 41.
2. Accounting Standards and Basis of Preparation
Functional currency and presentation currency, page F-14
6.We note your disclosures that beginning on July 1, 2022, the main Argentinian
subsidiaries changed their functional currency from Argentine Pesos to United States
Dollars.  Please provide us with a more comprehensive discussion of the specific facts and
circumstances of the events that led management to conclude that there was a change to
the functional currency of the main Argentinian subsidiaries and how management
concluded that the United States Dollar now reflects the underlying transactions, events
and conditions of these subsidiaries.  As part of your response, provide the specific
references to the guidance in IAS 21 that supports your conclusions.  Finally, provide
disclosures for this change that provides investors with a better understanding of these
facts and circumstances that led to the change in functional currency and how the change
in functional currency specifically impacted your consolidated financial statements here or
within MD&A.
4. Summary of Significant Accounting Policies
4.18 Revenue Recognition, page F-30
7.Please expand your accounting policy to provide the following information:
•A more comprehensive explanation of the methods used to recognize revenue for
services recognized over time per IFRS 15.124.
•When you recognize revenue for services are not able to be estimated reliably.
•Significant payment terms per IFRS 15.117 and IFRS 15.119(b).
•Obligations for returns, refunds, warranties, or other similar obligations per IFRS
15.119(d) and 119(e).
•A more comprehensive discussion of the significant judgments in estimating variable
consideration per IFRS 15.123 and 126.
6. Acquisitions and Other Significant Transactions
Syngenta Seedcare Agreement, page F-34
8.We note that you entered into an exclusive global distribution and R&D collaboration
agreement and also an exclusive supplier agreement with Syngenta on September 12,
2022.  Please provide us with a description of the material terms of both of the
agreements, your accounting for all of the material components in the contract and how
you are accounting for these agreements along with specific references to the applicable
authoritative literature.  Ensure that your response addresses the following:
•How you concluded that the $50 million upfront payment by Syngenta was only to be
allocated to the rights to use your trademarks even though the agreement also
includes the right to be an exclusive global distributor of certain of your products and
also the joint R&D program.  To the extent that you concluded that the right as an

 FirstName LastNameEnrique López Lecube
 Comapany NameBioceres Crop Solutions Corp.
 February 1, 2024 Page 4
 FirstName LastNameEnrique López Lecube
Bioceres Crop Solutions Corp.
February 1, 2024
Page 4
exclusive distributor of your products and the right to use your trademarks represents
one performance obligation, provide us with your analysis of the guidance in IFRS
15.31 through 38 such that the single performance obligations is satisfied at a point in
time rather than over time.  Refer to the guidance in IFRS 15.B48 through B62.
•For the sales-based royalty of 50% to 30% of the profits generated by sales conducted
by Syngenta depending on the geography and the year, please provide us with your
analysis of the material terms and the guidance in IFRS 15.B63 through B63B to
support your conclusion that the royalty revenues are to be recognized at the later of
when the performance obligation is satisfied or the sale occurs rather than as variable
consideration in accordance with IFRS 15.50 through 59.  Also address how the
minimum global target for royalties impacts your recognition of revenue.
•We note your statement that the products sold to Syngenta under the Supply
Agreement are set at fair market value.  Please explain what you mean by fair market
value and how Syngenta will be able to generate any gross profit, if they are buying
the products at the same price as any other market participant.
9. Taxation, page F-58
9.We note the reconciliation that you provide from the statutory tax rate to the effective tax
rate.  It does not appear that the beginning point of the reconciliation is earnings before
income tax multiplied by the Argentine statutory rate, as disclosed, for any period
presented.  Please tell us how your presentation for each period presented complies with
the disclosure requirements in IAS 12.81(c).  Further, please provide a comprehensive
explanation in MD&A for the material factors impacting the amount of income tax benefit
(expense) recognized for each period presented including quantification of those factors.
6-K Filed September 11, 2023
Exhibit No. 99.1
10.Please provide reconciliations for all non-GAAP financial measures presented for each
period presented from the most comparable financial measure or measures calculated and
presented in accordance with IFRS-IASB in accordance with Rule 100(a)(2) of Regulation
G, as interpreted by Question 102.10(b) of the Compliance and Disclosure Interpretations
for Non-GAAP Financial Measures.
            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.
            Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.

 FirstName LastNameEnrique López Lecube
 Comapany NameBioceres Crop Solutions Corp.
 February 1, 2024 Page 5
 FirstName LastName
Enrique López Lecube
Bioceres Crop Solutions Corp.
February 1, 2024
Page 5
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services