December 6, 2019

Jose Montero
Chief Financial Officer
Copa Holdings, S.A.
Avenida Principal y Avenida de la Rotonda, Costa del Este
Complejo Business Park, Torre Norte
Panama City, Panama

       Re: Copa Holdings, S.A.
           Form 20-F for the Fiscal Year ended December 31, 2018
           Filed April 24, 2019
           File No. 001-32696

Dear Mr. Montero:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

       Please respond to this comment within ten business days by providing the
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your

       After reviewing your response to this comment, we may have additional

Form 20-F for the Fiscal Year Ended December 31, 2018

Operating and Financial Review and Prospects
Liquidity and Capital Resources
Tabular Disclosure of Contractual Obligations, page 51

1.     We note that you report having $8.9 billion in aircraft and engine
purchase commitments
       as of December 31, 2018, although in the second paragraph on page 50,
and in financial
       statement Note 27 on page F-65, you indicate this amount is based on
aircraft list prices,
       rather than the specific terms of your agreements.

       The disclosures you provide under Item 5.F of Form 20-F should reflect
the amounts you
       are required and expect to pay under your purchase obligations, and
should include details
       of any provisions that are necessary to understand any material
uncertainty or variability
       in the timing and amounts of the specified obligations.

       The disclosures that you provide in your financial statements should
also include the
 Jose Montero
Copa Holdings, S.A.
December 6, 2019
Page 2
         actual amounts of contractual commitments for the acquisition of
property, plant and
         equipment to comply with paragraph 74(c) of IAS 16.

         Please describe the measures you will take to ensure that future
disclosures conform with
         these requirements. Tell us the amounts of aircraft and engine
purchase commitments as
         of December 31, 2018, and describe the changes you propose for the
table of contractual
         obligations and the corresponding note to your financial statements.
       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 Mark Wojciechowski, Staff Accountant, at 202-551-3759 or
Gallagher, Staff Accountant, at 202-551-3706 with any questions.

FirstName LastNameJose Montero                                Sincerely,
Comapany NameCopa Holdings, S.A.
                                                              Division of
Corporation Finance
December 6, 2019 Page 2                                       Office of Energy
& Transportation
FirstName LastName