United States securities and exchange commission logo
August 8, 2023
Gerardo Cruz Celaya
Chief Financial Officer
Coca-Cola FEMSA, S.A.B. de C.V.
Calle Mario Pani No. 100
Santa Fe Cuajimalpa
Cuajimalpa de Morelos
05348, Ciudad de M xico, M xico
Re: Coca-Cola FEMSA,
S.A.B. de C.V.
Form 20-F for the
Year Ended December 31, 2022
Filed April 17,
2023
Form 6-K Filed July
26, 2023
File No. 001-12260
Dear Gerardo Cruz Celaya:
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 Year Ended December 31, 2022
Consolidated Financial Statements
Note 3. Significant Accounting Policies
3.14 Intangible assets, page F-26
1. We note your accounting
policy and disclosures regarding your treatment of TCCC
bottling agreement
intangible assets as indefinite lived intangible assets even though they
appear to have stated
terms of 10 years and contain a 10 year renewal right. Please refer
to paragraph 94 of IAS
38 and more fully explain to us why you believe your accounting
policy is appropriate
and consistent with IFRS, given the stated terms stipulated in the
agreements. In
addition, please more fully explain to us the process and expected costs of
renewing the agreements
at the end of the 10 year term and address if the agreements
Gerardo Cruz Celaya
Coca-Cola FEMSA, S.A.B. de C.V.
August 8, 2023
Page 2
provide for successive renewal periods after the initial 10 year
renewal term.
Form 6-K filed on July 26, 2023
General
2. We note that you define EBITDA on a consolidated basis as operating
income plus
depreciation, amortization and other operating non-cash charges.
Please be advised that
Question 103.01 of the Division of Corporation Finance s Compliance
and Disclosure
Interpretations on Non-GAAP Financial Measures indicates that EBITDA
is defined as
earnings before interest, taxes, depreciation and amortization .
Please revise the non-
IFRS measure you present as EBITDA to only include adjustments for
items
contemplated by its acronym or revise the title of the non-IFRS
measure you present to
convey the additional adjustments. In addition, if you continue to
present either EBITDA
or Adjusted EBITDA on a consolidated basis, please be advised that
Question 103.02 of
the Division of Corporation Finance s Compliance and Disclosure
Interpretations on Non-
GAAP Financial Measures requires these measure to be reconciled to the
most directly
comparable IFRS measure which is net income rather than operating
income.
3. We note that you present percentage changes related to numerous IFRS
measures, on both
a consolidated and segment basis, that you identify as "comparable".
We also note that
you broadly define the nature of the items excluded from comparable
percentage changes
but do not quantify the impact of each excluded item for each
comparable percentage
change. It appears to us this results in presenting non-IFRS measures
but not providing
reconciliations to the most directly comparable IFRS measures. In
regard to the
comparable percentage changes you present, please tell us your
consideration of the the
requirements of Item 100(a)(2) of Regulation G.
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 Jeffrey Gordon at 202-551-3866 or Anne McConnell at
202-551-
3709 with any questions.
FirstName LastNameGerardo Cruz Celaya Sincerely,
Comapany NameCoca-Cola FEMSA, S.A.B. de C.V.
Division of
Corporation Finance
August 8, 2023 Page 2 Office of
Manufacturing
FirstName LastName