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                              December 14, 2022

       He Yu
       Chairman and Chief Executive Officer
       Kuke Music Holding Ltd
       Building 96, 4 San Jian Fang South Block
       Chaoyang District
       Beijing, 100024
       The People   s Republic of China

                                                        Re: Kuke Music Holding
Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-3
                                                            Filed November 18,
2022
                                                            File No. 333-267655

       Dear He Yu:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 28, 2022 letter.

       Amendment No. 1 to Registration Statement on Form F-3 filed November 18,
2022

       Prospectus Summary
       Our Contractual Arrangements, page 2

   1.                                                   We note your response
to comment 12, as well as your revised disclosure that "a result of
                                                        our direct ownership in
the WFOEs and the contractual arrangements with the VIE, we
                                                        have become the primary
beneficiary of the VIEs for accounting purposes and, therefore,
                                                        have consolidated the
financial results of the VIEs in our consolidated financial statements
                                                        in accordance with the
IFRS." Please revise to state that the arrangements enable you to
                                                        receive the economic
benefits of the VIEs, be the primary beneficiary for accounting
 He Yu
FirstName
Kuke MusicLastNameHe
            Holding LtdYu
Comapany14,
December  NameKuke
              2022    Music Holding Ltd
December
Page 2    14, 2022 Page 2
FirstName LastName
         purposes, and consolidate your financial statements to the extent you
have satisfied the
         conditions for consolidation of the VIEs under IFRS. Additionally,
revise your disclosure
         that you "exercise effective control over the VIEs" to refrain from
implying that such
         contractual arrangements are equivalent to ownership in the VIE, for
example by
         discussing your ability to direct the activities of the VIEs (as you
do on page 25). Make
         conforming changes on the cover page and page 24.
Approvals Required from the PRC Authorities for Offering Securities to Foreign
Investors, page
6

2.       Please state affirmatively whether you, your subsidiaries or the VIEs
have received all
         requisite permissions or approvals to offer the securities being
registered, disclose any
         such required permissions or approvals (or state that none are
required), and state
         whether any permissions or approvals have been denied. Such disclosure
should cover
         permissions or approvals from PRC authorities including, but not
limited to, the CSRC
         and CAC. Please revise your disclosure that "our PRC counsel advises
that we are not
         subject to the cybersecurity review by the CAC for the offering" to
ensure that it covers
         any permissions or approvals pertaining to you, your subsidiaries or
the VIEs that are
         required to offer the securities.
3.       Please revise to disclose the consequences if you, your subsidiaries,
or the VIEs do not
         receive required permits or approvals to offer the registered
securities, "inadvertently
         conclude that such permissions or approvals are not required . . . or
if PRC government
         authorities promulgates any interpretation or implements rules" that
would require you to
         obtain such permits or approvals. In this regard, your current
disclosure does not appear
         to cover the consequences applicable to your subsidiaries or the VIEs.
Permissions Required from the PRC Authorities for Our Operations, page 6

4.       We note your response to comment 9. Please revise to identify "[y]our
consolidated
         affiliated entities" or, to the extent such term refers to the VIEs,
revise to use the term "the
         VIEs." Here and throughout the prospectus where you discuss licenses
and permits,
         revise to refer to permissions and approvals instead. State
affirmatively whether any
         permissions or approvals related to your operations have been denied.
Revise the
         reference to "licenses and permits . . . that are material for the
business operations" to
         delete the materiality qualifier. As it appears that you are not
relying on an opinion of
         counsel with respect to your conclusions regarding the permits and
approvals required to
         operate your business, state that is the case, explain why you did not
receive such an
         opinion and explain the basis for your conclusions.
5.       We note your disclosure that "we cannot assure you that we have
obtained all the permits
         or licenses required for conducting our business in China, and we may
inadvertently
         conclude that permissions or approvals are not required," as well as
your disclosure that
         "[w]e may be required to obtain additional licenses, permits, filings
or approvals for our
         businesses in the future." Please revise to describe the consequences
to you and your
 He Yu
Kuke Music Holding Ltd
December 14, 2022
Page 3
      investors if you, your subsidiaries, or the VIEs (and not just "we"): (i)
do not receive or
      maintain such permissions or approvals, (ii) inadvertently conclude that
such permissions
      or approvals are not required, or (iii) applicable laws, regulations, or
interpretations
      change and you are required to obtain such permissions or approvals in
the future.
Recent Developments, page 19

6.    Please delete as inappropriate your statement that "prospective investors
are cautioned not
      to place undue reliance on such information."
General

7.    We note your response to comment 4. Given that your Hong Kong
subsidiaries
      participate in the transfer of cash/assets in your organization, please
discuss China's
      Enterprise Tax Law and the arrangement between mainland China and the
Hong Kong
      Special Administrative Region for the Avoidance of Double Taxation and
the Prevention
      of Fiscal Evasion. If true, disclose on the cover page that any
regulatory actions related to
      data security or anti-monopoly concerns in Hong Kong do not and will not
impact your
      ability to conduct your business, accept foreign investment or list on a
foreign exchange.
       You may contact Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at
202-551-3222 if
you have any questions.



                                                            Sincerely,
FirstName LastNameHe Yu
                                                            Division of
Corporation Finance
Comapany NameKuke Music Holding Ltd
                                                            Office of Trade &
Services
December 14, 2022 Page 3
cc:       Dan Ouyang
FirstName LastName