SEC Comment Letter 0000000000-23-011035 to Innovation Beverage Group Ltd (IBG) (CIK 0001924482) (IBG)
Innovation Beverage Group Ltd (IBG) (CIK 0001924482)
Date: Oct. 6, 2023 · CIK: 0001924482 · Accession: 0000000000-23-011035
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File numbers found in text: 333-266965
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United States securities and exchange commission logo
October 6, 2023
Dean Huge
Chief Executive Officer
Innovation Beverage Group Ltd
29 Anvil Road
Seven Hills, NSW 2147
Australia
Re:Innovation Beverage Group Ltd
Amendment No. 19 to Registration Statement on Form F-1
File No. 333-266965
Filed September 29, 2023
Dear Dean Huge:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 19 to Registration Statement on Form F-1
Unaudited Interim Consolidated Financial Statements
Consolidated Balance Sheets, page F-23
1.Refer to the December 31, 2022 balance sheet column and reconcile with the amounts
disclosed on the December 31, 2022 balance sheet shown on page F-3, as we note certain
amounts do not agree. Also, please label all of the columns on the unaudited interim
statements of operations and comprehensive loss, stockholders' equity and cash flows as
unaudited, as we note you have only designated the June 30, 2023 columns as unaudited.
Further, on page F-36 (Note 10 - Income Taxes), provide a reconciliation of the effective
tax rate to statutory rate for the comparative six months ended June 30, 2022, as your
current disclosure provides the reconciliation for the year ended December 31, 2022.
FirstName LastNameDean Huge
Comapany NameInnovation Beverage Group Ltd
October 6, 2023 Page 2
FirstName LastName
Dean Huge
Innovation Beverage Group Ltd
October 6, 2023
Page 2
Please contact Beverly Singleton at 202-551-3328 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Evan Ewing at 202-551-5920 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing