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Innovation Beverage Group
Limited

29 Anvil Road

Seven Hills, NSW 2147

Australia

November 22, 2022

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Sherry Haywood and Evan Ewing

    Re:
    Innovation Beverage Group Ltd

    Amendment No. 8 to the Registration Statement on Form F-1

    File No. 333-266965

    Filed November 15, 2022

Dear Ms. Haywood and Mr. Ewing:

Innovation Beverage Group
Ltd (the “Company” or “IBG”) previously submitted Amendment No. 8 to the Company’s
Registration Statement on Form F-1 (the “Registration Statement”) pursuant to Title I, Section 106 under the
Jumpstart Our Business Startups Act with the Securities and Exchange Commission (the “Commission”) on November
15, 2022. Amendment No. 9 responds to the comment letter received on November 21, 2022 from the staff of the Commission (the “Staff”).
For ease of review, we have set forth below the comment of your letter followed by the Company’s response thereto.

Capitalization, page 39

 1. Refer
                                            to the pro forma column. It appears the amount of cash and cash equivalents should be $8,300,744,
                                            based on the net proceeds from the Unit offering of $8,830,500, less the $600,000 payment
                                            on the notes payable. Similarly, it appears the ordinary shares should have a value of $13,553,611
                                            after giving effect to the net proceeds. Please revise your computations accordingly, including
                                            the total shareholders’ equity and total capitalization, or expand disclosures to describe
                                            any other pro forma adjustments.

Response: The Company acknowledges the Staff’s comment
and has made the requested revisions.

Dilution, page 40

 2. Refer
                                            to your disclosure of adjusted net tangible book value as of June 30, 2022. Based on the
                                            net proceeds from the Unit offering, it appears this amount should instead be $9,803,844
                                            with a related per share amount of $0.98. Please revise your disclosures and dilution calculations
                                            accordingly, or advise.

Response: The Company acknowledges the Staff’s comment
and has made the requested revisions.

Filing Fee Table, page II-5

 3. Please
                                            provide your analysis of how your calculation of the “Maximum Aggregate Offering Price”
                                            is consistent with Rule 457. Specifically, we note that in addition to 2,500,000 units, you
                                            have provided the underwriters an option to purchase up to an additional 375,000 ordinary
                                            shares and/or up to an additional 375,000 warrants to cover over-allotments.

Response: The Company acknowledges the
Staff’s comment and respectfully advises that the calculation is such that an aggregate amount of 2,875,000 units will be
offered, which is comprised of 2,500,000 units and the over-allotment amount of 375,000 ordinary shares and/or warrants, and when
multiplied by the public offering price of $4.15, results in a maximum aggregate offering price of $11,931,250. The exercise price
of the warrants is not yet determined, therefore, the calculation assumes an exercise price that is the same as the public offering
price (or 100% of the per unit public offering price).

Further, with respect to the ordinary shares
underlying the Underwriter Warrants, if the underwriter exercises its over-allotment option in full, the underwriter will receive
a warrant to purchase up to 5% of the aggregate ordinary shares sold in the offering, or 143,750 ordinary shares, which has an
exercise price of equal to 120% of the public offering price, or $4.98, and when multiplied by such price results in $715,875.

Exhibit 107 has been revised to reflect these
calculations.

Exhibits

 4. We
                                            note that you may have redacted information from Exhibit 4.5. If you are redacting information
                                            pursuant to Item 601(b)(10)(iv) of Regulation S-K, please explain why you may rely on Item
                                            601(b)(10)(iv) to redact information filed pursuant to Item 601(b)(4) and mark the exhibit
                                            index to indicate that portions of your exhibits have been omitted. Additionally, please
                                            refile to clearly indicate where information is omitted in Exhibit 4.5. If you are not relying
                                            on Item 601(b)(10)(iv) of Regulation S-K for Exhibit 4.5, refile the exhibit without the
                                            statement on the first page stating that certain information has been redacted.

Response: The Company acknowledges the
Staff’s comment and has refiled the exhibit without the statement of redaction as the Company is no longer relying upon Item
601(b)(10)(iv) of Regulation S-K.

Should you have any questions
regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia Ross Ference
LLP at (212) 930-9700.

    Sincerely

    Dean Huge

    Chief Executive
    Officer

cc:	Darrin Ocasio