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CORRESP
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    Linklaters LLP

    1290 Avenue of the Americas

    New York, NY 10104

    Telephone (+1) 212 903 9000

    Facsimile (+1) 212 903 9100

    matthew.poulter@linklaters.com

March 1, 2024

Via EDGAR Submission

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

  Attention:
  Ms. Tracey Houser

Mr. Terence O’Brien

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

Ms. Houser and Mr. O’Brien:

Bioceres Crop Solutions Corp.
(the “Company”) previously submitted to the Securities and Exchange Commission (the “SEC”) on November 14,
2023, an annual report on Form 20-F for the year ended June 30, 2023 (the “Form 20-F”), and on September 11,
2023, a current report on Form 6-K which includes an earnings release for the year ended June 30, 2023.

On behalf of the Company,
we are writing to respond to the comments set forth in the comment letter (the “Comment Letter”) from the staff of
the SEC (the “Staff”) dated February 1, 2024. The Company’s responses below correspond to the captions and
numbers of those comments (which are reproduced below in bold).

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.

The Company acknowledges the Staff’s
comments and plans to include disclosure similar to the below, which includes net profit, in the Company’s annual report on Form 20-F
for the year ended June 30, 2024 and in future annual reports to be filed with the SEC:

We are a global company, and our agricultural
inputs are marketed across more than 45 countries, primarily in South America, the United States and Europe. Our total revenue, net profit
and adjusted EBITDA for the year ended June 30, 2023 totaled US$420.1 million, US$20.2 million and US$81.2 million, respectively.
Adjusted EBITDA is a non-IFRS financial measure. See “Item 5. Operating and Financial Review and Prospects—A. Operating Results—Non-IFRS
Financial Measures” and “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business” for information
regarding our use of Adjusted EBITDA and a reconciliation of net profit to Adjusted EBITDA.

Further, the Company acknowledges the
Staff’s comments and respectfully clarifies that in its most recent earnings release for the six-month period ended December 31,
2023, which was furnished to the SEC on Form 6-K on February 9, 2024, it drafted its disclosure to comply with Item 10I(1)(i)(A) of
Regulation S-K and Questions 102.10(a) and 102.10(b) of the Compliance and Disclosure Interpretations for Non-GAAP Financial
Measures. In addition, the Company will draft its disclosure in future filings to comply with Item 10I(1)(i)(A) of Regulation S-K
and Questions 102.10(a) and 102.10(b) of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.

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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.

The Company acknowledges the Staff’s
comments and plans to include disclosure similar to the below in the Company’s annual report on Form 20-F for the year ended
June 30, 2024 and in future annual reports to be filed with the SEC:

Revenues from contracts with customers
and initial recognition and changes in the fair value of biological assets at the point of harvest

Total revenue for the year ended June 30,
2023 totaled $420.1 million, an increase of 25% when compared to the year ended June 30, 2022. Pro Farm revenue and the accrual of
the upfront fee from the Syngenta Exclusive Global Distribution Agreement contributed $41.0 million and $32.9 million, respectively, of
the increased revenue for the period. This increase in total revenue was achieved despite strong historical results for the year ended
June 30, 2022 and a number of external factors that challenged growth, including a drought of historical magnitude in Argentina and
negative industry dynamics in the U.S. and Brazil.

Crop
Protection. Total revenue increased by $31.4 million, to $205.8 million for the year ended June 30, 2023, from
$174.4 million for the year ended June 30, 2022. This increase represents an 18% growth rate and includes $31.1 in revenue from Pro
Farm’s bio-protection products. Excluding this Pro Farm revenue, crop protection revenue remained almost flat, as the segment faced
significant headwinds from adverse weather conditions and high levels of channel inventories in several geographies. Adjuvant sales also
remained almost flat at $50 million despite a 17% reduction in sales volume.

Crop
Nutrition. Total revenue increased by $48.2 million, to $157.3 million for the year ended June 30, 2023, compared
to $109.1 million for the year ended June 30, 2022. At 44% growth year over year, crop nutrition saw the largest yearly increase
of all three segments. Segment growth was driven by: (i) the $32.9 million accrual of the upfront fee from the Syngenta Exclusive
Global Distribution Agreement, (ii) an increase of $10.0 million in micro-beaded fertilizer sales due to higher fertilizers prices
(which more than offset the decrease in sales volume), and (iii) $9.8 million in sales from Pro Farm’s bio-stimulants.

Seed
and Integrated Products. Total revenue increased by $5.4 million, to $56.7 million for the year ended June 30,
2023, compared to $51.3 million for the year ended June 30, 2022, an 11% increase. The increase was mainly driven by a $4.7 million
increase in HB4 sales, resulting from greater sales volume when compared to the previous fiscal year, followed by increases of $3.4 million
and $0.6 million in seed treatment packs and royalty payments, respectively. These revenue increases were partially offset by the initial
recognition and changes in the fair value of biological assets.

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Gross profit

Total gross profit
increased by $58.2 million, to $184.6 million for the year ended June 30, 2023, from $126.4 million for the year ended June 30,
2022, which was mainly driven by the $32.9 million upfront fee accrual under the Exclusive Global Distribution Agreement with Syngenta,
$24.9 million from the incorporation of Pro Farm products and $1.2 million from the R&D Collaboration Agreement with Syngenta.

The crop nutrition
segment achieved a 57% of gross margin compared to 43% in the previous year, mainly driven by positive results from the agreements with
Syngenta for the global distribution of inoculants, as well as growth in micro-beaded fertilizers sales with higher prices. Gross profit
in crop protection increased due to the inclusion of $16.8 million from Pro Farm products. Excluding these items, gross profit for this
segment was almost flat year over year, in line with sales performance. The incorporation of Pro Farm products into the portfolio increased
the average margin for this segment from 29% to 33%. Finally, despite higher sales, gross profit contribution from Seed & Integrated
Products decreased by 13%, heavily impacted by product mix.

Further, in respect of additional disclosure
relating to Syngenta, the Company respectfully notes that, although the Exclusive Global Distribution Agreement was already in force as
of June 30, 2023, no significant results in relation to the variable consideration component were recognized in the year ended June 30,
2023 due to operational delays in launching the distribution arrangement. The Company will add further disclosure relating to the impact
of the upfront fee in future filings.

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.

In response to the Staff’s comment,
the Company respectfully clarifies that its Argentine subsidiaries are “subject to certain restrictions on payments
of foreign indebtedness through the foreign exchange market (the “FX Market”).” Although there are limitations on
the ability of the Argentine subsidiaries to make payments of foreign indebtedness through the foreign exchange market (which are discussed
in more detail in the Form 20-F), these limitations are not a total restriction that would completely preclude these subsidiaries
from making payments abroad. Although these restrictions exist, the Company understands that its Argentine subsidiaries are able to meet
their foreign debt obligations. In addition, the Company does not consider it necessary to disclose in which jurisdictions it
holds its cash and cash equivalents, the amount of debt held outside of Argentina and how payments are made on such debt.

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 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.

The Company acknowledges the Staff’s
comments and plans to include disclosure similar to the below in the Company’s annual report on Form 20-F for the year ended
June 30, 2024 and in future annual reports to be filed with the SEC:

Even though earnings before interest,
taxes and depreciation increased, cash generated by operating activities reached $2.6 million for the year ended June 30, 2023, due
to our incremental working capital outflow. This was mainly driven by an increase in trade receivables of $56.9 million, recoverable income
tax of $16.2 million and other receivables of $11.5 million. The severe drought in Argentina negatively impacted our clients and in turn
payment terms for trade receivables and other receivables. Days of sale and inventory outstanding increased by an average of 15%, while
days payables outstanding remained almost flat in the year ended June 30, 2023 when compared to the year ended June 30, 2022.

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 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.

The Company acknowledges the Staff’s
comments and understands that presenting the sum of revenues from contracts with customers, initial recognition and changes in fair value
of biological assets at the point of harvest, and changes in the net realizable value of agricultural products after harvest is in accordance
with IAS 1.85 and is relevant to assist investors to understand the performance of the Company’s comprehensive income for each fiscal
year. Such line items are measured in accordance with IFRS, and the sum of these items is presented in a clear and understandable way
for all comparative periods with the same prominence as subtotals required to be presented under IFRS. However, the Company respectfully
clarifies that in the Forms 6-K furnished to the SEC (i) on November 29, 2023, which included its unaudited interim condensed
consolidated financial statements as of September 30, 2023 and June 30, 2023, and for the three-month periods ended September 30,
2023 and 2022, and (ii) on February 28, 2024, which included its unaudited interim condensed consolidated financial statements
as of December 31, 2023 and June 30, 2023, and for the three and six-month periods ended December 31, 2023 and 2022, the
total line for such line items were not presented, and the Company will follow this approach in future filings.

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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.

The Company acknowledges the Staff’s
comment and clarifies that in accordance with IAS 21.9 and 21.10, it has considered the following factors to determine the functional
currency of its subsidiaries:

 i. Currency: the sales prices for goods and services are mainly influenced and deter