June 10, 2019

Calvin Choi
Chief Executive Officer
AMTD International Inc.
23/F Nexxus Building
41 Connaught Road Central
Hong Kong

       Re: AMTD International Inc.
           Draft Registration Statement on Form F-1/A
           Submitted on May 28, 2019
           CIK No. 0001769731

Dear Mr. Choi:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted May 28,
2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Components of Results of Operations
Revenue, page 70

1.     We note the additional disclosures on page 71 in response to our comment
17. We also
       note that the weighted average asset management fee rate decreased from
0.55% in 2017
       to 0.45% in 2018 to 0.16% in the three months ended March 31, 2019.
Please revise to
       discuss the significant change in your weighted average fee rate for the
periods presented.
 Calvin Choi
FirstName LastNameCalvin Choi
AMTD International Inc.
Comapany NameAMTD International Inc.
June 10, 2019
Page 2
June 10, 2019 Page 2
FirstName LastName
Consolidated Statements of Financial Position, page F-4

2.       Please revise your next amendment to provide consistent presentation
in the assets and
         liabilities sections of the Consolidated Statements of Financial
Position for current and
         non-current assets and liabilities. You list non-current assets first
in the assets section and
         non-current liabilities second in the liabilities section.
Notes to Consolidated Financial Statements
Note 2.3. Summary of Significant Accounting Policies
Revenue Recognition, page F-21

3.       We note your response to our comment 22. Please revise your next
amendment to
         disclose information about the methods, inputs and assumptions used in
allocating the
         transaction price, including estimating stand-alone selling prices of
promised goods or
         services in accordance with paragraph 126(c) of IFRS 15.
Note 4. Operating Segment Information, page F-24

4.       We note your response and related revisions to our comment 24. Please
revise your next
         amendment to include the required disclosures, including revenues from
customers in
         different geographical areas for each reporting segment, in accordance
with paragraph 33
         of IFRS 8. Refer to paragraphs 31, 33 and BC 52 of IFRS 8.
Note 23. Related Party Transactions, page F-43

5.       Please revise your next amendment to disclose required information
regarding your due to
         fellow subsidiaries and due to immediate holding company balances for
the periods
         presented in accordance with ASC 850-10-50. Make a corresponding
change to the
         related party transaction note to the interim financial statements.
Note 26. Financial Risk Management Objectives and Policies, page F-50

6.       We note your response and related revisions to the second bullet point
in our comment
         28. Please revise your next amendment to address all the required
disclosures in Item 11
         of Form 20-F related to equity price risk in the Quantitative and
Qualitative Disclosures
         about Market Risk section for your strategic investments.
 Calvin Choi
AMTD International Inc.
June 10, 2019
Page 3

       You may contact Stephen Kim at 202-551-3291 or David Irving at
202-551-3321 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Livingston at 202-551-3448 or Michael Clampitt at 202-551-3434
with any other
questions.



FirstName LastNameCalvin Choi                             Sincerely,
Comapany NameAMTD International Inc.
                                                          Division of
Corporation Finance
June 10, 2019 Page 3                                      Office of Financial
Services
FirstName LastName