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                            March 28, 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. 24 to
Registration Statement on Form F-1
                                                            File No. 333-266965
                                                            Filed March 27,
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. 24 to Registration Statement on Form F-1

       Capitalization , page 44

   1.                                                   Please address the
following items.

                                                              Tell us how you
arrived at the 811,075 shares, as the total share issuances since July
                                                            1, 2023 and through
March 27, 2024, instead appear to be 761,075 ordinary shares
                                                            based on the
history of share capital and recent sales of unregistered securities, as
                                                            disclosed on pages
103 and II-3, respectively. Please revise or explain the 50,000
                                                            share difference.
It might be useful to provide a reconciliation within a footnote.
                                                              Please ensure
your pro forma ordinary shares ($6,579,855) is computed accurately. It
                                                            might be useful to
provide a reconciliation within a footnote.
                                                              Explain why the
pro forma accumulated deficit would not be impacted by certain
                                                            ordinary share
issuances which occurred since July 1, 2023, as disclosed on pages
 Dean Huge
FirstName
Innovation LastNameDean
           Beverage GroupHuge
                          Ltd
Comapany
March      NameInnovation Beverage Group Ltd
       28, 2024
March2 28, 2024 Page 2
Page
FirstName LastName
              103 and II-3. It might be useful to provide a reconciliation
within a footnote.
                We note the capitalization table is nine months old, as of June
30, 2023. Tell us the
              consideration given to providing a more updated Capitalization
table as of a date no
              earlier than 60 days prior to the most recent amendment date.
Refer to Item 3.B. of
              the Form 20-F.

Dilution, page 46

2.       Refer to the second paragraph on page 46 and provide us with your
computation of pro
         forma net tangible book value, and related per share amount, as of
June 30, 2023, which
         gives effect to the issuance of 811,075 ordinary shares. Similarly,
for the third paragraph,
         provide us with your computation of pro forma as adjusted net tangible
book value and
         related per share amount, after giving effect to the sale of 1,250,000
units.

History of Share Capital, page 102

3.       We note the disclosures on page 103 and also under Recent Sales of
Unregistered
         Securities on page II-3 that on February 27, 2024 you issued an
aggregate of 219,915
         ordinary shares to two employees with an aggregate value of
USD$434,839, and on
         March 27, 2024 you issued an aggregate of 117,083 ordinary shares to
two employees
         with an aggregate value of USD$234,166. It appears that the
aforementioned transactions
         (issued at USD$2.00 per share) were issued at a significant discount
to your IPO Unit
         offering price of $4.125 per unit. Please address the following items.
             If applicable, tell us why you believe these share issuances are
not below the fair
              market value of the your pending IPO.
             Revise your disclosure (e.g., within recent developments on page
13, footnotes to
              your capitalization table on pages 44-45, and elsewhere in the
registration statement,
              as necessary) to explain how you will account for the per share
price difference in
              your financial statements, such as additional compensation
expense pursuant to ASC
              718.


       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 Geoffrey Kruczek at 202-551-3641 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing
 Dean Huge
Innovation Beverage Group Ltd
FirstName
March 28, 2024 LastNameDean Huge
Comapany
Page    3      NameInnovation Beverage Group Ltd
March 28, 2024 Page 3
cc:       Darrin M. Ocasio
FirstName LastName