We evaluate the amplitude for gammagamma --> pi0pi0 to two loops in ch
iral perturbation theory. The three new counterterms which enter at th
is order in the low-energy expansion are estimated with resonance satu
ration. We find that the cross section agrees rather well with the ava
ilable data and with dispersion theoretic calculations even substantia
lly above threshold. Numerical results for the Compton cross section a
nd for the neutral pion polarizabilities are also given to two-loop ac
curacy.