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                             September 12, 2022

       Dean Huge
       Chief Executive Officer
       Innovation Beverage Group Ltd
       29 Anvil Road
       Seven Hills, NSW 2147
       Australia

                                                        Re: Innovation Beverage
Group Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            File No. 333-266965
                                                            Filed September 7,
2022

       Dear Mr. Huge:

             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
September 2, 2022 letter.

       Amendment No. 1 to Registration Statement on Form F-1

       Exhibit Index, page II-5

   1.                                                   To the extent that you
are redacting information pursuant to Item 601(b)(10)(iv) of
                                                        Regulation S-K, please
mark the exhibit index to indicate that portions of your exhibits
                                                        have been omitted.
Additionally, please clearly indicate where the information is omitted
                                                        in Exhibit 4.5. If you
are not relying on Item 601(b)(10)(iv) of Regulation S-K for Exhibit
                                                        4.5, refile the exhibit
without the statement on the first page stating that certain
                                                        information has been
redacted.
 Dean Huge
Innovation Beverage Group Ltd
September 12, 2022
Page 2
Signatures, page II-6

2.       The registration statement must be signed by your principal financial
officer and
         principal accounting officer or controller. Additionally, any person
who occupies more
         than one of the specified positions, for example, principal financial
officer and
         principal accounting officer or controller, must indicate each
capacity in which he signs
         the registration statement. Refer to instructions 1 and 2 of Form F-1
and revise.
General

3.       We note that the form of warrant included in Exhibit 4.5 provides that
all legal
         proceedings concerning the interpretations, enforcement and defense of
the transactions
         contemplated by the warrant shall be commenced exclusively in the
state and federal
         courts sitting in the city of New York, and that the company
irrevocably submits to such
         exclusive jurisdiction. Please disclose whether this provision applies
to actions arising
         under the Securities Act or Exchange Act. If so, please also state
that there is uncertainty
         as to whether a court would enforce such provision. If the provision
applies to Securities
         Act claims, please also state that investors cannot waive compliance
with the federal
         securities laws and the rules and regulations thereunder. In that
regard, we note that
         Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
         over all suits brought to enforce any duty or liability created by the
Securities Act or the
         rules and regulations thereunder. If this provision does not apply to
actions arising under
         the Securities Act or Exchange Act, please also ensure that the
exclusive forum provision
         in the governing documents states this clearly, or tell us how you
will inform investors in
         future filings that the provision does not apply to any actions
arising under the Securities
         Act or Exchange Act.
       You may contact Beverly Singleton at 202-551-3328 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Evan Ewing at 202-551-5920 or Sherry Haywood at 202-551-3345 with any
other
questions.



FirstName LastNameDean Huge                                     Sincerely,
Comapany NameInnovation Beverage Group Ltd
                                                                Division of
Corporation Finance
September 12, 2022 Page 2                                       Office of
Manufacturing
FirstName LastName