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CORRESP
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 Thunder Power Holdings, Inc.

 221 W 9th St #848

 Wilmington, Delaware 19801

 BY EDGAR

 April 14, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 Washington, D.C. 20549

 Attn:
 Thomas Jones

 Jay Ingram

 RE:
 Thunder Power Holdings, Inc.

 Preliminary Proxy Statement on Schedule 14A

 Filed March 7, 2025

 Mr. Jones and Mr. Ingram:

 Thunder Power Holdings, Inc. (the " Company "),
a Delaware corporation, hereby submits this letter in response to the comments set forth in that certain letter dated March 20, 2025 from
the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") to the
Company, relating to the preliminary proxy statement on Schedule 14A that the Company filed with the Commission on March 7, 2025.

 The Company is responding to the Staff's
comments by filing Amendment No. 2 to the proxy statement (" Amendment No. 2 ") that addresses the Staff's comments,
as more fully set forth below. For your convenience, the Staff's comments have been retyped herein in bold.

 Comment 1
 Results of Operations, page 13

 We note that you present US dollar equivalents
in the tables included in this section. Please revise to disclose your reason for, and the rates used in, providing this convenience translation
for investors. You should disclose the rates used to translate all income statement as well as balance items presented.

 Response

 In response to the comment, we have revised the
remove all the US dollar reference for consistency with the audited financial statements of Electric Power Technology Limited. Please
refer to pages 29 to 35.

 Comment 2
 Financial Statements of Electric Power Technology Limited and its Subsidiaries, page F-3

 Please revise the filing to include financial
statements of Electric Power Technology Limited that are audited by an independent accountant in accordance with either (i) the standards
of the PCAOB or (ii) U.S. generally accepted auditing standards ("U.S. GAAS"). See Rule 1-02(a)(d) of Regulation S-X. Further,
revise the filing to include a report issued by your independent accountant that complies with the requirements of Rule 2-02 of Regulation
S-X.

 Response

 In response to the comment, we have included financial
statements of Electric Power Technology Limited that are audited in accordance with U.S. generally accepted auditing standards ("U.S.
GAAS"). Please refer to page F-5.

 Thunder Power Holdings, Inc.

 221 W 9th St #848

 Wilmington, Delaware 19801

 Comment 3
 Financial Statements of Electric Power Technology Limited and its Subsidiaries, page F-3

 Have your auditor revise its report to indicate,
and please revise the financial statements to clearly disclose the accounting principles and practices reflected therein. Include a clear
statement in the accounting policy note to indicate whether the financial statements were prepared using IFRS as issued by the IASB. Otherwise,
revise to include the reconciliations to U.S. GAAP required by Item 18 of Form 20-F. This comment also applies to your interim financial
statements.

 Response

 The Company respectfully submits it is working
with the TW Company to update the financial statements under IFRS issued by IASB.

 Comment 4
 Financial Statements of Electric Power Technology Limited and its Subsidiaries, page F-3

 Please remove the ‘Notice to Readers'
currently included on page F-11, or tell us why that disclosure is appropriate.

 Response

 In response to the comment, we have revised and
removed the "Notice to Readers" that were originally included on page F-11.

 Comment 5
 Accountant's Review Report, page F-79

 Please have your independent accountant revise
its review report to comply with (i) the standards of the PCAOB or (ii) US GAAS. In addition, we note that the first sentence of the report
indicates that your independent accountant audited the balance sheets of the company as of September 30, 2024 and 2023 and the related
consolidated statements of income, changes in equity, and cash flows for the nine months then ended, and the related notes to the consolidated
financial statement. Have your auditor remove this reference to an audit, or advise us. Lastly, please note that a review report is not
usually required when providing unaudited interim financial statements in filings.

 Response

 The Company submits that as Electric Power Technology
Limited has released its financial statements for the year ended December 31, 2024, the Company has removed the reviewed financials statement
covering the nine-month periods ended September 30, 2023 and 2024. As Electric Power Technology Limited would qualify as an emerging growth
company, the Proxy Statement currently included the audited financial statements of Electric Power Technology Limited for the years ended
December 31, 2023 and 2024.

 If you have any further questions or comments,
or would like to discuss this response letter, please feel free to call contact undersigned at christopher.nicoll@aiev.ai or Elizabeth
Chen of Pryor Cashman LLP, outside counsel to the Company, at echen@pryorcashman.com (tel:212-326-0199).

 Sincerely,

 /s/ Christopher Nicoll

 Christopher Nicoll

 Chief Executive Officer