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                             April 14, 2023

       Emilio Ca  avate
       Chief Financial Officer
       Turbo Energy, S.A.
       Plaza de Am  rica
       Number 2, 4B
       Val  ncia, Spain 46004

                                                        Re: Turbo Energy, S.A.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted March 31,
2023
                                                            CIK No. 0001963439

       Dear Emilio Ca  avate:

             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 Confidential Draft Registration Statement on Form F-1

       Cover Page

   1.                                                   We note your revisions
in response to comment 2. Given Enrique Selva Bellvis'
                                                        ownership of Umbrella
Solar Investment and Crocodile Investment, please revise to
                                                        identify Mr. Bellvis as
a controlling shareholder here and in your disclosure on page 27.
 Emilio Ca  avate
FirstName   LastNameEmilio Ca  avate
Turbo Energy,   S.A.
Comapany
April       NameTurbo Energy, S.A.
       14, 2023
April 214, 2023 Page 2
Page
FirstName LastName
Risk Factors
We are dependent on a limited number of suppliers for our batteries, inverters,
and photovoltaic
modules and the inability of these supplier, page 20

2.       We note in your disclosure that you experienced a supply constraint
with Chinese
         suppliers in 2022. Please expand you disclosure regarding this
constraint and the effects
         such constraint had on the Company's business.
Principal Shareholders, page 66

3.       We note your response to comment 13 and reissue in part. We note you
have excluded
         shares from the beneficial ownership of Mr. Bellvis. Please revise
each
         individual's beneficial ownership to include all shares each
individual beneficially owns,
         whether or not also beneficially owned by another person or entity in
the table, which can
         be explained in the footnotes. In the alternative, please explain how
you determined that
         Mr. Bellvis does not have beneficial ownership of the shares held by
Umbrella
         Investment.
Related Party Transactions, page 67

4.       Please revise your disclosure to comply with Item 4(a) of Form F-1 and
Item 7(B) of
         Form 20-F.
Financial Statements
Note 10 - Related Party Transactions, page F-16

5.       We note your response to prior comment 15; however, based on the
disclosed amounts of
         related party transactions that occurred during the period, please
more fully explain why
         the cash flows for related party advances and repayments significantly
exceed the related
         party transaction amounts. In addition, based on your response and the
nature of the
         related party transactions, please also more fully explain how you
determined the related
         party cash flows are appropriately classified as financing activities
under IAS 7.
6.       We note your response to prior comment 16. In regard to the first
bullet, please disclose
         the information you provided in your response in note 10 and also
disclose the number of
         entities the parent company allocates expenses to. We also note your
response to the
         second and third bullets indicates the historical financial statements
appropriately reflect
         all costs of doing business and no additional costs would be required
to be reflected in
         historical or pro forma financial statements. Please also disclose
this information in note
         10.
 Emilio Ca  avate
FirstName   LastNameEmilio Ca  avate
Turbo Energy,   S.A.
Comapany
April       NameTurbo Energy, S.A.
       14, 2023
April 314, 2023 Page 3
Page
FirstName LastName
        You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at
202-551-
3709 if you have questions regarding comments on the financial statements and
related
matters. Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at
202-551-3454 with any
other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing
cc:       Louis A. Bevilacqua