United States securities and exchange commission logo





                              October 11, 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. 6 to
Registration Statement on Form F-1
                                                            File No. 333-266965
                                                            Filed October 3,
2022

       Dear Dean 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.

       Amendment No. 6 to Registration Statement on Form F-1

       Summary Consolidated Financial Data, page 13

   1.                                                   Please expand this
section to also include the consolidated statements of operation data for
                                                        the years ended
December 31, 2021 and 2020. In this regard, this section should include
                                                        consolidated statements
of operation data for all periods presented in the filing.

       Capitalization, page 38

   2.                                                   Refer to the
shareholders' equity section of the table and address the following:

                                                              Clarify that the
total number of issued and outstanding ordinary shares, actual, at June
 Dean Huge
Innovation Beverage Group Ltd
October 11, 2022
Page 2
              30, 2022, to be 7,496,340 as shown in the balance sheet on page
F-5, and reflect the
              total ordinary shares dollar values on this line item, thereby
deleting the line item
              additional paid-in capital.
                Revise the line item description of accumulated other
comprehensive income to
              instead be accumulated other comprehensive loss.
                Revise the line item description of retained earnings to
instead be accumulated
              deficit.

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
40

3.       Please revise your sections of results of operations and liquidity and
capital resources to
         also include the previous discussion for the fiscal year ended
December 31, 2021
         compared to December 31, 2020. Refer to Instruction 1 to Item 303(b)
of Regulation S-K
         as MD&A must cover the audited the financial statements presented in
the filing. The
         current discussion of the interim financial statements for the six
months ended June 30,
         2022 and 2021 should continue to be provided in the filing.

       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 Jay Ingram at 202-551-3397 with any other
questions.



FirstName LastNameDean Huge                                    Sincerely,
Comapany NameInnovation Beverage Group Ltd
                                                               Division of
Corporation Finance
October 11, 2022 Page 2                                        Office of
Manufacturing
FirstName LastName