SecProbe.io

March 20, 2020
Andreas Spiegler
Chairman and Chief Executive Officer
Industrial Technical Holdings Corporation
Huanxiu Street Office, Shuanglong Industrial Park
266201 Jimo
Qingdao, China
Re:Industrial Technical Holdings Corporation
Amendment No. 4 to Registration Statement on Form F-1
Filed March 11, 2020
File No. 333-233613
Dear Mr. Spiegler:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our March 3, 2020 letter.
Amendment No. 4 to Registration Statement on Form F-1 filed March 11, 2020
Ordinary Shares, page 107
1.We note your response to prior comment 2.  If the provision referenced in that comment
includes liabilities under the federal securities laws, please revise to state so directly.
Please also clarify whether this provision effectively functions to nullify any shareholder
claims, and/or as a waiver of the ability of shareholders to bring any claims, against the
company and its directors and officers.  Also, we note the disclosure on page 14 regarding
the consequences in the event a shareholder’s certificate is the subject of a fraudulent
transfer or transaction.  Please expand to clarify how the provision could result in a loss of
“some or all of [a shareholder’s] investment.”  Also tell us why you believe the risk is

 FirstName LastNameAndreas  Spiegler
 Comapany NameIndustrial Technical Holdings Corporation
 March 20, 2020 Page 2
 FirstName LastName
Andreas  Spiegler
Industrial Technical Holdings Corporation
March 20, 2020
Page 2
limited to fraudulent transfers or transactions.  Ensure your disclosure clearly and fully
explains the material risks presented by the provision.
Related Party Transactions, page 108
2.Please expand your revisions in response to prior comment 3 to clarify the purpose of the
arrangements you describe, including why your officers pay the expenses instead of
the company making payment directly.
Exhibits
3.We note your response to prior comment 6.  Please file each counsel’s consent expressly
stating that counsel consents to the summarization of its opinion, as currently set forth on
page 13.
            You may contact Michael Fay at (202) 551-3812 or Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 if you have questions regarding comments on the financial statements
and related matters.  Please contact Geoff Kruczek at (202) 551-3641 or Russell Mancuso at
(202) 551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Andrew J. Befumo, Esq.