September 10, 2018

Martin G. King
Chief Financial Officer
Philip Morris International Inc.
120 Park Avenue
New York, New York 10017

       Re: Philip Morris International Inc.
           Form 10-K for the Year Ended December 31, 2017
           Form 10-Q for the Quarter Ended March 31, 2018
           File No. 001-33708

Dear Mr. King:

       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 10-K for the Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Consolidated Operating Results, page 22

1.     We note your disclosure on pages 24 and 59 of how excluding the impact
of certain
       inventory movements affected your shipment volumes and the cigarette
market. Please
       clarify the nature of these "inventory movements." Your response and
revised disclosure
       should fully explain what the inventory movements are and how excluding
such
       movements affects your reported results.
 Martin G. King
Philip Morris International Inc.
September 10, 2018
Page 2
Form 10-Q for the Quarter Ended March 31, 2018

Note 18. New Accounting Standards, page 36

2.       We note from your disclosure in Note 7, that net revenues refers to
your operating
         revenues from the sale of products, including shipping and handling
charges billed to
         customers, net of sales and promotion incentives, and excise taxes. In
light of the fact that
         the incentives appear to represent variable consideration, please tell
us and revise to
         disclose the nature of all variable consideration and how you estimate
the variable
         consideration, including whether this estimate is typically
constrained. See ASC 606-10-
         50-12(c) and 606-10-50-20. In this regard, we also note from your
earnings calls that you
         may have loyalty programs associated with the IQOS products, which
also may be sold
         with discounts. Please note that these programs should be considered
in your variable
         consideration analysis.
       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 Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameMartin G. King                                Sincerely,
Comapany NamePhilip Morris International Inc.
                                                                Division of
Corporation Finance
September 10, 2018 Page 2                                       Office of
Transportation and Leisure
FirstName LastName