SecProbe.io

August 21, 2024
Zhi Feng Ang
Chief Financial Officer
VCI Global Limited
B03-C-8 & 10, Menara 3A
KL Eco City, No.3 Jalan Bangsar
59200 Kuala Lumpur
Malaysia
Re:VCI Global Limited
Form 20-F for the Fiscal Year Ended December 31, 2023
Filed April 30, 2024
File No. 001-41678
Dear Zhi Feng Ang:
            We have reviewed your filing and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2023
Item 5. Operating and Financial Review and Prospects
A. Operating Results, page 27
1.Please expand your disclosure to address the performance of your operating segments,
including the reasons for the changes in “net profit” for each of your segments discussed
in Note 31 of your financial statements. In circumstances where there is more than one
reason for a change between periods, please quantify the incremental impact of each
individual reason on the overall change. Refer to Item 5 of Form 20-F, including the
interpretative releases listed in Instruction 1 thereto.
Item 15. Controls and Procedures, page 61
Please tell us why you did not include disclosures regarding your evaluation of disclosure
controls and procedures and internal controls over financial reporting. Please note that the
exemption from assessing disclosure controls and procedures and internal controls over 2.

August 21, 2024
Page 2
financial reporting is only applicable to an issuer that has not previously filed an annual
report with the Commission for the prior fiscal year. We note you previously filed an
annual report on Form 20-F for the fiscal year ended December 31, 2022. Refer to Item 15
of Form 20-F and to 17 CFR 240.13a-15 of the Rules and Regulations Under the
Securities Exchange Act of 1934.
Item 19. Exhibits
Exhibits 13.1 and 13.2, page 64
3.We note that the certifications provided as Exhibit 13.1 and Exhibit 13.2 do not include
the introductory language in paragraph 4 referring to your internal control over financial
reporting. Please explain. Refer to Instruction 12 as to Exhibits of Form 20-F for further
details.
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-6
4.Please tell us your basis from presenting "Advances made to related parties" as a
financing activity referencing authoritative literature that supports your treatment.
22. Revenue, page F-37
5.On pages F-20 and F-21 you disclose that revenues from business strategy consultancy
services and technology development contracts are generally recognized over time;
however, the table on age F-37 indicates that the majority of your revenues are recognized
at a point in time. Please reconcile these disclosures for us.
28. Income Tax Expense, page F-39
6.Explain to us why a substantial portion of your fiscal 2023 income was "Non-taxable
income" and explain the nature of "Unabsorbed tax losses" and how you accounted for
these unabsorbed losses referencing authoritative literature that supports your accounting
treatment. Consider adding disclosure in this regard in future filings.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact James Giugliano at 202-551-3319 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services