May 8, 2019

Felipe Dutra
Chief Financial and Solutions Officer
Anheuser-Busch InBev SA/NV
Brouwerijplein 1
3000 Leuven, Belgium

       Re: Anheuser-Busch InBev SA/NV
           Form 20-F for Fiscal Year Ended December 31, 2018
           Filed March 22, 2019
           File No. 001-37911

Dear Mr. Dutra:

       We have reviewed your filing 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 Fiscal Year Ended December 31, 2018

Item 5. Operating and Financial Review
E. Results of Operations, page 82

1.    Please disclose the business reasons for material changes between periods
in each
      segment's operating results (e.g., revenues, material expense line items
and profit). In
      circumstances where more than one business reason exists for a change
between periods,
      also quantify the incremental impact of each individual business reason.
Refer to Item
      5.A of Form 20-F.
Consolidated Financial Statements
Note 5. Segment Reporting, page F-26

2.    Please tell us how you determined that no individual foreign country had
material
      revenues from external customers requiring disclosure pursuant to
paragraph 33(a) of
      IFRS 8.
 Felipe Dutra
Anheuser-Busch InBev SA/NV
May 8, 2019
Page 2

        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 Suying Li at (202) 551-3335 or Rufus Decker at (202)
551-3769 with
any questions.



                                                          Sincerely,
FirstName LastNameFelipe Dutra
                                                          Division of
Corporation Finance
Comapany NameAnheuser-Busch InBev SA/NV
                                                          Office of Beverages,
Apparel and
May 8, 2019 Page 2                                        Mining
FirstName LastName