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Galaxy Payroll Group
Limited

25th Floor, Ovest

77 Wing Lok Street

Sheung Wan, Hong Kong

May 9, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade &Services

100 F Street, N.E

Washington, DC 20549

Attn: Brian Fetterolf and Donald Field

 Re: Galaxy Payroll Group Ltd

Amendment No. 9 to Registration Statement on Form F-1

Filed April 10, 2024

File No. 333-269043

Dear Mr. Fetterolf and Mr. Field,

This letter is being furnished
in response to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange
Commission (the “Commission”) that were contained in the Staff’s letter dated May 2, 2024 (the “Comment Letter”)
to Galaxy Payroll Group Ltd (the “Company” or “Galaxy”) with respect to the Amendment No. 9 to Registration Statement
on Form F-1.

This letter provides the Company’s
responses to the Staff’s comments contained in the Comment Letter. The text of the Staff’s comments is set forth in bold below,
followed by the responses of the Company.

Amendment No. 9 to Registration Statement on Form F-1 filed April
10, 2024

Industry, page 81

 1. Please update your discussion of industry data as of a more recent date, to the extent available. As examples,
we note your disclosure that “the total employed population in the PRC was approximately 780.2 million in 2021 . . . ,” that
“the share of GDP of the service industry has been steady, at around 41.8% in 2022,” and that “there were approximately
340,000 SMEs in Hong Kong with around 1.7 million employees, accounting for approximately 45% of total employment in Hong Kong as of May
2022.”

Response: In
response to the Staff’s comment, the Company has updated the disclosure on pages 82, 83, 84 of the Amendment No. 10 to the Registration
Statement on Form F-1 (“F-1/A No.10”) accordingly.

General

 2. Please advise (i) the circumstances under which the selling shareholders received
the ordinary shares covered by the resale offering, as well as how long the selling shareholders have held such shares, (ii) why the resale
offering is being registered at this time, (iii) whether the resale offering is being registered at this time to satisfy any Nasdaq listing
requirements, (iv) how you determined the number of ordinary shares being registered in connection with the resale offering, and (v) how
the selling shareholders were selected to participate in this resale offering (given the lock-up applicable to other principal shareholders),
all with a view to understanding whether the resale portion of the offering should be deemed an indirect primary being conducted by or
on behalf of the issuer. Refer to Question 612.09 of the Securities Act Rules Compliance and Disclosure Interpretations.

Response: The
Company acknowledges the Staff’s comment and respectfully note to the Staff the following:

Factor 1: the circumstances
under which the selling shareholders received the ordinary shares covered by the resale offering, as well as how long the selling shareholders
have held such shares

The three selling
shareholders, i.e., New Basic Group Limited, who holds 640,000 shares, First Start International Limited, who holds 960,000 shares, and
Dynamic Ally Investments Limited, who holds 640,000 shares, as disclosed in the F-1/A No.10, are all founding members who invested in
the Company since its incorporation on August 2021 (the “Establishment”). All of them have held the shares since then.

Factor 2: why the
resale offering is being registered at this time

The Selling Shareholders
would like to have the flexibility to sell their shares upon the completion of the initial public offering (the “IPO”) for
their personal financial planning need.

Factor 3: whether
the resale offering is being registered at this time to satisfy any Nasdaq listing requirements

No. The Company believes
it satisfies the Nasdaq listing requirements without the resale offering.

Factor 4: how you
determined the number of ordinary shares being registered in connection with the resale offering

The number of ordinary
shares registered for resale from the Selling Shareholders represents 100% of the shares they have held since the Establishment. The registration
of these shares were requested by the Selling Shareholders.

Factor 5: how the
selling shareholders were selected to participate in this resale offering (given the lock-up applicable to other principal shareholders)

As discussed under
Factor 4, the request was made by three of the Company’s 14 founding shareholders. The Company has not received any such request
for the rest founding shareholders.

In addition, the proposed
resale is not to be underwritten by the underwriter. The Selling Shareholders have no relationship with the underwriter. We do not believe
it is an indirect primary offering. Instead, it is appropriately characterized as a secondary offering under the guidance provided by
the Compliance and Disclosure Interpretation Question 612.09 (“C&DI 612.09”), considering the factors summarized above.

We thank the Staff for your
review of the foregoing. If you have any questions, please do not hesitate to contact the undersigned at frank.lao@galaxy-hk.com, or Elizabeth
Fei Chen of Pryor Cashman LLP, outside counsel to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

    Very truly yours,

    By:
    /s/ Wai Hong Lao

    Name:
    Wai Hong Lao

    Title:
    Chief Executive Officer

    cc:
    Elizabeth Fei Chen, Esq.