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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

April 11, 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

    Response Letter Dated March 1, 2024

    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”).

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 March 14, 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 5. Operating and Financial Review and
Prospects

B. Liquidity and Capital Resources, page 77

 1. We note your response to comment 3. We note your statement that the limitations on your Argentine subsidiaries
ability to make payments on foreign indebtedness discussed are not total restrictions. Please provide a robust discussion of how the Argentine
subsidiaries are able to meet their foreign debt obligations in light of the discussed limitations, the amount of foreign debt, and the
amount of cash and cash equivalents either disaggregated by geography or by currency denomination or provide us with a detailed explanation
as to why this additional information is not useful to investors. 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 clarifies that its Argentine subsidiaries do not have any outstanding foreign indebtedness. Therefore, the risk factor disclosure
contained on page 20 of the Form 20-F relating to restrictions on payments of foreign indebtedness through the foreign exchange
market is not relevant to the Company’s Argentine subsidiaries. In light of the foregoing, the Company understands that it would
not be useful to investors to provide disclosure which presents cash and cash equivalents disaggregated by geography or by currency denomination.
In order to reflect this position properly, in future filings the Company will delete the last paragraph of the risk factor captioned
 “Our indebtedness could adversely affect our financial condition.”

2. Accounting Standards and Basis of Preparation

Functional currency and presentation currency,
page F-14

 2. We note your response to comment 6, including the draft disclosures you intend to provide in your fiscal
year 2024 Form 20-F. Please expand your draft disclosures to provide a more comprehensive, company specific explanation of the facts
and circumstances, including the time period these facts and circumstances occurred, that led management to re-evaluate the Argentine
entities’ functional currency. Refer to IAS 21.54 for guidance.

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

From July 1, 2022, our main Argentine
subsidiaries changed their functional currency from the Argentine Peso to the U.S. dollar as a result of changes in events and conditions
that are relevant to their business operations, which include a hyper inflationary macroeconomic context and the depreciation of the Argentine
Peso, in addition to the effects on our business of certain business combination transactions, as discussed below.

    2

Macroeconomic
context – in recent years Argentina’s macroeconomic scenario has featured a misalignment between inflation
rates and the devaluation of the Argentine peso, which became more pronounced during the first half of the year ended June 30, 2022.
Notwithstanding such misalignment, our Argentine subsidiaries have been able to continue pricing their products in U.S. dollars as the
costs of products and services are set in U.S. dollars. This has also been achievable as the demand for the type of products we commercialize
is relatively inelastic when compared to non-essential goods and services. Further, Argentina’s significant economic volatility
has caused materials, and other costs of providing goods that we acquire from the Argentine domestic market, to become increasingly indexed
to the U.S. dollar (i.e., denominated in Argentine Pesos but indexed to the U.S. dollar exchange rate).

Business
effects –we also note that, following the merger with Pro Farm, which closed at the beginning of the fiscal year
ended June 30, 2023, in addition to other business combination transactions reported in our financial statements, we established
a global commercial strategy with a view to unifying pricing policies for the commercialization of our products.

In accordance with IAS 21, we have
considered the following primary factors to determine the functional currency of our main Argentine subsidiaries: (i) the sales prices
for goods and services, which are mainly influenced and determined by the U.S. dollar; and (ii) the increasing influence of transactions
indexed to the U.S. dollar related to labor, materials, and other costs of providing goods.

Taking into account the analysis of
the primary factors provided by IAS 21 in determining the functional currency of our main Argentine subsidiaries (in particular the increased
influence of exchange rates on their costs of operations, which are indexed to the U.S. dollar), we identified that there is strong evidence
that their functional currency had changed to the U.S. dollar.

As discussed above, we assessed primary
indicators and determined that they were conclusive for the analyzed period; however, consideration was also given to secondary indicators.
The result of such analysis also leads to the conclusion that the U.S. dollar is the relevant currency for cash generation from operating
and financing activities of our main Argentine subsidiaries.

The effects of the change in functional
currency were recorded prospectively.

4. Summary of Significant Accounting Policies

4.18 Revenue Recognition, page F-30

 3. As previously requested in comment 7, please disclose the significant payment terms in accordance with
IFRS 15.117 and IFRS 15.119(b). In this regard, stating that invoices are issued with the usual payment terms for each geographical region
does not provide investors with an understanding of the timing of cash flows arising from contracts with customers, as required by IFRS
15.110. In this regard, we note that as of December 31, 2023, the trade receivables balance of $199.7 million exceeds the $140.3
million of revenues recognized during the second quarter of fiscal year 2024.

    3

The Company acknowledges the Staff’s
comments and plans to expand its disclosure on its revenue recognition policy, including the significant payment terms, similar to the
below in its annual report on Form 20-F for the fiscal year ended June 30, 2024 and in future annual reports to be filed with
the SEC:

Typically, our average payment
terms range from 130 to 160 days at a consolidated level. Longer terms may be granted in limited circumstances; however, the effects of such sales are not
material to our consolidated financial statements. Those payment terms do not contain a significant financing component.

Further, the Company respectfully clarifies
that the balance of trade receivables exceeds revenues recognized during the second quarter of fiscal year ended June 30, 2024 due
to the average days of receivables exceeding 90 days. In addition, the Company respectfully notes that, while the days of sales outstanding
as of December 31, 2023 remained consistent with historical performance, such figures were influenced by the severe drought in Argentina,
which impacted market conditions in recent years.

6. Acquisitions and Other Significant Transactions

Syngenta Seedcare Agreement, page F-34

 4. We note your response to comment 8. Please provide us with your analysis of the facts and circumstances
that supports your conclusion that the license for intellectual property rights is distinct from the other promised goods and services.
In this regard, we note your statement that the manufacturing and sale of products and the R&D services are dependent on the license.
Refer to IFRS 15.B52 through B56. To the extent that the facts and circumstances do not support a conclusion that the license is distinct,
provide us with your analysis regarding whether the license is the predominant item to which the royalties relate. Refer to IFRS 15.B63A.

The Company acknowledges the Staff’s
comment and respectfully clarifies that, in accordance with its analysis of the paragraphs B52 to B56 of IFRS 15, it concluded that the
license for intellectual property rights is distinct from the other promised goods and services as the customer may benefit from the license
together with readily available resources other than the Company’s manufacturing and R&D services. The manufacturing process
used to produce the products is currently available in the market, and R&D services focused on developing new products, are not unique
or specialized, and several other entities also have the ability to manufacture the relevant products and provide such services to Syngenta.

The Company also concluded that its
promises to grant the license and to provide the manufacturing and R&D services are separately identifiable (i.e., the criterion in
paragraph 27(b) of IFRS 15 is met). On the basis of the principle and the factors of paragraph 29 of IFRS 15, the Company concluded
that the license, the manufacturing and the R&D services are not inputs to a combined item in the agreement. When reaching this conclusion,
the Company considered that Syngenta could separately purchase the license without significantly affecting its ability to benefit from
it. Neither the license, nor the services, are significantly modified or customized by the other and the Company is not providing a significant
service of integrating those items into a combined output.

The Company further considered that
the license and each service are not highly interdependent or highly interrelated as the Company would be able to fulfill its promise
to transfer the license independently of fulfilling its promise to subsequently manufacture products and provide R&D services to Syngenta.
Similarly, the Company would be able to manufacture products and provide R&D services even if Syngenta had previously obtained the
license and initially utilized a different manufacturer or provider.

    4

The Company notes that the license and
the services do not significantly affect each other. Consequently, the Company concluded that its promises to grant the license and to
provide manufacturing and R&D services are distinct and separable performance obligations.

 5. Please provide us with the disclosures you intend to provide for the life of this agreement detailing
the material terms, including your obligations under the agreements, your accounting for the agreements, the critical accounting estimates,
and the impact to your consolidated financial statements for the periods presented.

The Company acknowledges the Staff’s
comments and will expand its disclosure relating to this agreement similar to the below in its annual report on Form 20-F for the
fiscal year ended June 30, 2024 and in future annual reports to be filed with the SEC:

Syngenta Seedcare Agreement

On September 12, 2022, we entered
into a ten-year Exclusive Global Distribution Agreement with Syngenta Crop Protection AG (“Syngenta”), pursuant to which Syngenta
will be the exclusive global distributor of certain of our biological solutions for seed care applications (the “Agreement”).
Products included within the scope of the Agreement include nitrogen-fixing Rhizobia seed treatment solutions (inoculants), and other
biological seed and soil treatment solutions. We have retained global rights for the use of products for HB4® crops; and, in the United
States, Syngenta rights are non-exclusive for upstream applications. Pro Farm’s biological solutions are not included within the
scope of the Agreement. On October 6, 2022, Syngenta made an upfront payment of $50 million as consideration under the Agreement.
Concurrently with the Agreement, we entered into an R&D Collaboration Agreement and a Supply Agreement with Syngenta, which are discussed
below.

The exclusive commercial collaboration
is applicable for all countries, except for Argentina where both parties will continue to work under the existing framework. The Agreement
is effective as of January 1, 2023, but its implementation was staggered as we continued distributing our products in certain countries
during calendar year 2023. Syngenta will cover all operating expenses incurred in connection with marketing and sales in the exclusive
territory.

In addition, concurrently with the
Agreement, we entered into a Supply Agreement with Syngenta, whereby we act as the exclusive supplier of the products under the Agreement.
The manufactured products will be purchased by Syngenta at a price equivalent to the production cost plus a profit margin, to be agreed
upon by the parties in compliance with applicable laws. Consequently, for purposes of complying with transfer pricing regulations, the
price to be paid will be a price equivalent to market conditions for an exclusive supply agreement and Syngenta will determine the resale
price for end-customers.

    5

Further, we entered into an R&D
Collaboration Agreement that establishes a joint R&D program to accelerate the global development and registration of our products
pipeline and new solutions for seed treatment, foliar and other applications. Except for “late development products” (as defined
in the Agreement) which will be funded by us, funding of the R&D program will be shared between Syngenta and us, with Syngenta contributing
up to 70% of the investment. The R&D Collaboration Agreement falls within the provisions of IFRS 11, as a joint operation agreement,
based on the contractual rights and obligations of each party. We recognize our direct right to and share of any jointly held or incurred:
assets, liabilities, revenues and expenses. The R&D activities relating to “late development products,” the cost of which
will be funded by us, are within the scope of IFRS 15.

In accordance with IFRS 15, we have
determined three performance obligations which are distinct from each other: (i) licensing of intellectual property rights; (ii) manufacturing;
and (iii) R&D services. The license, the manufacturing and R&D services are not inputs to a combined item and they are separately
identifiable. Syngenta can benefit from the license together with readily available resources other than the manufacturing and R&D
services. The manufacturing process used to produce the products and R&D services are not unique or specialized and several other
entities can also manufacture the product and provide the services to Syngenta.

 (i) Licensing of biological intellectual property rights

We identified a right to use license
of intellectual property rights, which relates to biological products, such as patents, inventions, information, data (including registration
data), know-how, among others. The license granted has significant independent functionality and it is not expected that we will undertake
activities that significantly affect the intellectual propert