United States securities and exchange commission logo
September 1, 2023
Juan Ignacio Urthiague
Chief Financial Officer
Globant S.A.
37A Avenue J.F. Kennedy
L-1855 Luxembourg
Re: Globant S.A.
Form 20-F for the
fiscal year ended December 31, 2022
filed February 28,
2023
File No. 001-36535
Dear Juan Ignacio Urthiague:
We have limited our review of your filing to the financial
statements and related
disclosures and 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 business days by
providing the requested
information or advise 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 fiscal year ended December 31, 2022
Item 5. Operating and Financial Review and Prospects
B. Liquidity and Capital Resources, page 73
1. We refer you to the
table on page 74 that discloses three amounts that sum to become total
capital expenditures of
$99,848 and $89,625 for the fiscal years ending December 31,
2022 and 2021,
respectively. Please tell us why these amounts do not reconcile with the
IFRS measures
containing similar descriptions in the investing activities in your
statements of cash
flows.
Notes to the Consolidated Financial Statements
Note 3 Summary of Significant Accounting Policies
3.2 Goodwill, page F-18
2. We note your policy
states that you allocate goodwill to a unique cash generating unit.
Juan Ignacio Urthiague
Globant S.A.
September 1, 2023
Page 2
Please tell us how you applied the requirements in paragraph 65 of
IAS 36 in your
determination of a unique cash generating unit. In doing so
specifically tell us how you
identified cash generating units in accordance with paragraphs 68 to
73, and how
you allocated goodwill acquired in business combinations to a cash
generating unit, or
groups of cash generating units, that is expected to benefit from the
synergies of the
combination, as outlined in paragraphs 80 to 87 of the Standard.
In closing, 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.
You may contact Brian McAllister at(202) 551-3341 or Shannon Buskirk at
(202) 551-
3717 with any questions.
FirstName LastNameJuan Ignacio Urthiague Sincerely,
Comapany NameGlobant S.A.
Division of
Corporation Finance
September 1, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName