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                            June 29, 2023

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

                                                        Re: Innovation Beverage
Group Ltd
                                                            Amendment No. 14 to
Registration Statement on Form F-1
                                                            File No. 333-266965
                                                            Filed June 23, 2023

       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.
Unless we note
       otherwise, our references to prior comments are to comments in our June
7, 2023 letter.

       Amendment No. 14 to Registration Statement on Form F-1

       Capitalization, page 44

   1.                                                   We note your inclusion
of footnote (4), which appears to be a discussion for a non-GAAP
                                                        measure of net loss.
Please delete this footnote from within the table and also the
                                                        related disclosure in
footnote (4)(i) through (vi), and the sentence that immediately
                                                        follows regarding your
recurring net losses during the period.

   2.                                                   Refer to the pro forma
column in the table. Based on your newly inserted disclosure that
                                                        this column gives
effect to the conversion of debt of US$630,000 for the issuance of
                                                        221,533 ordinary
shares, it appears the Notes payable line item amount should reflect a
 Dean Huge
Innovation Beverage Group Ltd
June 29, 2023
Page 2
         balance of US$931,131 and the total capitalization should be
US$1,856,831 rather than
         US$2,846,931. Please revise. Further, the pro forma as adjusted column
should be
         revised accordingly to reflect the IPO and application of the net
proceeds, including the
         repayment of US$600,000 of notes payable to the seller of Reg Liquors
LLC.
Exhibits

3.       Notwithstanding your assertion in your response to comment 2 that
corresponding
         changes were made, we are not able to locate the revisions nor a
written justification for
         why the cited language is appropriate. We therefore reissue comment 2
of our prior
         letter.
       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
June 29, 2023 Page 2                                           Office of
Manufacturing
FirstName LastName