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                           August 18, 2023

       Wai Yiu Yau
       Chief Executive Officer
       Globavend Holdings Ltd
       Office 1401, Level 14, 197 St Georges Tce,
       Perth, WA 6000,
       Australia

                                                        Re: Globavend Holdings
Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted August 4,
2023
                                                            CIK No. 0001978527

       Dear Wai Yiu Yau:

             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 on Form F-1 submitted
August 4, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 60

   1.                                                   In response to prior
comment 3, you disclosed the amounts of the foreign exchange gains
                                                        for the years ended
September 30, 2021 and 2022. We re-issue the comment. Please
                                                        revise your discussion,
to the extent material to an understanding of your results of
                                                        operations, to quantify
for each period presented the impact that foreign currency
                                                        movement had on
specific line items of revenue and expenses. Refer to Item 5.A.3. of
                                                        Form 20-F.
 Wai Yiu Yau
Globavend Holdings Ltd
August 18, 2023
Page 2
Cash Flow
Operating Activities, page 66

2.       We note the additional disclosure added in response to prior comment
7. We re-issue the
         comment. Please revise your discussion of operating cash flow to
discuss the underlying
         drivers for the material changes of the components of the operating
cash flows between
         periods. Refer to SEC Release No. 33-8350, Section IV for guidance.
Our Competitive Strengths, page 70

3.       We note your response to prior comment 8. You indicate that you
purchased shipping
         solution software in 2019 that was modified internally to meet the
company's internal
         need. However, your disclosure on page 71 indicates that your software
is "self-
         developed" and you "have internally developed [your] own proprietary
all-in-one shipping
         solution." Please revise this disclosure to indicate that you
purchased software and
         internally modified such software.
Our Strategies, page 72

4.       We note your response to prior comment 9 and reissue it in part. You
state here that you
         plan to further expand your "logistics network and business presence
in Australia and
         New Zealand" and at page 24 that you "intend to hire additional staff
in Hong Kong and
         Australia to facilitate [your] expansion plans." Please further
discuss your plans to expand
         your business in Hong Kong and New Zealand.
MANAGEMENT
Employment Agreements and Indemnification Agreements, page 94

5.     We note your response to prior comment 10, including your having filed,
at Exhibit
FirstName LastNameWai Yiu Yau
       10.2, the employment agreement entered with Mr. Wai Yiu Yau, your Chief
Executive
Comapany    NameGlobavend
       Officer. Please updateHoldings  Ltd in this section to reflect the
agreement with Mr.
                             your disclosure
AugustWai   Yiu Yau
        18, 2023  Pageand
                       2 describe its material terms.
FirstName LastName
 Wai Yiu Yau
FirstName
Globavend LastNameWai
           Holdings Ltd Yiu Yau
Comapany
August 18, NameGlobavend
           2023           Holdings Ltd
August
Page 3 18, 2023 Page 3
FirstName LastName
        You may contact Steve Lo, Staff Accountant, at (202) 551-3394 or
Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding
comments on the
financial statements and related matters. Please contact Liz Packebusch, Staff
Attorney, at (202)
551-8749 or Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any
other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation
cc:      Virginia Tam