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                           September 21, 2022

       Daniel J. McClory
       Executive Chairman
       Brera Holdings Limited
       Connaught House, 5th Floor
       One Burlington Road
       Dublin 4
       D04 C5Y6
       Ireland

                                                        Re: Brera Holdings
Limited
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted September
2, 2022
                                                            CIK No. 0001939965

       Dear Mr. McClory:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

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

       Notes to the Consolidated Financial Statements for the Years Ended
December 31, 2021 and
       2020
       Note 1 - General information and reorganization transaction, page F-7

   1.                                                   We have reviewed your
response to comment 8 noting it does not appear to address our
                                                        comment. Your response
states you have identified the transaction between Brera
                                                        Holdings and KAP as a
common control transaction because the original shareholders of
                                                        KAP own 35% of the
outstanding shares of Brera Holdings. Please tell us how you
 Daniel J. McClory
Brera Holdings Limited
September 21, 2022
Page 2
      considered the guidance in IFRS 3 B2. In particular, please clarify if
there is a contractual
      arrangement with these individual shareholders that provides them with
the collective
      power to govern the company. If so, please provide us with a copy of the
contractual
      arrangement.

      In addition, please tell us how you determined that 35% ownership of the
outstanding
      shares constitutes control.
2.    Please provide us with the details (i.e., number of shares issued) of the
July 18, 2022
      transaction to purchase of all the shares of Brera Milano. In addition,
please provide us
      with a copy of the agreement.
       You may contact Abe Friedman at 202-551-8298 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Lilyanna Peyser at 202-551-3222 with any
other
questions.



                                                            Sincerely,
FirstName LastNameDaniel J. McClory
                                                            Division of
Corporation Finance
Comapany NameBrera Holdings Limited
                                                            Office of Trade &
Services
September 21, 2022 Page 2
cc:       Louis A. Bevilacqua
FirstName LastName