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                               March 15, 2024

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

                                                        Re: Innovation Beverage
Group Ltd
                                                            Amendment No. 22 to
Registration Statement on Form F-1
                                                            File No. 333-266965
                                                            Filed March 7, 2024

       Dear Dean Huge:

            We have reviewed your amended registration statement and have the
following
       comment(s).

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

       Amendment No. 22 to Registration Statement on Form F-1

       Related Party Transactions, page 95

   1.                                                   Please revise this
section to include the required information as of the latest practicable
                                                        date. Refer to Item 7.B
of Form 20-F.
       Index to Consolidated Financial Statements, page F-1

   2.                                                   We note your December
31, 2022 audited financial statements are older than 12 months
                                                        at the date of this
amended registration statement. Please be advised that since this is
                                                        an initial public
offering of your Units with each unit consisting of one ordinary share and
                                                        one warrant, you are
required to provide updated annual financial statements and related
                                                        disclosures pursuant to
Item 8.A.4 of Form 20-F or, if applicable, you should provide the
                                                        representations
required by Instruction 2 to Item 8.A.4 in an exhibit to the filing.
 Dean Huge
Innovation Beverage Group Ltd
March 15, 2024
Page 2

       Please 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
March 15, 2024 Page 2                                    Office of
Manufacturing
FirstName LastName