SEC Comment Letter 0000000000-24-011100 to VCI Global Ltd (VCIG)
VCI Global Ltd
Date: Oct. 1, 2024 · CIK: 0001930510 · Accession: 0000000000-24-011100
AI Filing Summary & Sentiment
File numbers found in text: 001-41678
Letter
October 1, 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 Response dated September 6, 2024 File No. 001-41678 Dear Zhi Feng Ang: We have reviewed your September 6, 2024 response to our comment letter and have the following comments. 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. Unless we note otherwise, any references to prior comments are to comments in our August 21, 2024 letter. Form 20-F for the Fiscal Year Ended December 31, 2023 Item 15. Controls and Procedures, page 61 1.We note your proposed disclosure in response to our prior comment 2 states your internal controls over financial reporting has been audited by WWC, P.C., an independent registered public accounting firm. Please include their report in your amendment or remove this statement. Refer to Item 15(b)(4) and Item 15(c) of Form 20-F. Consolidated Financial Statements Consolidated Statements of Cash Flows, page F-6 2.We reviewed your response to prior comment 4. Please consider revising the line item description to more accurately indicate the nature of the cash flows.
October 1, 2024 Page 2 Note 28. Income Tax Expense, page F-39 3.We note your response to our prior comment 6. Please expand your disclosure in future filings to explain the nature of, and reason for, the "non-taxable income" and "unabsorbed tax losses." General 4.When filing your amended 20-F, please include the entirety of Parts I, II and III, including any exhibits that require updating (i.e., certifications pursuant to sections 302 and 906 of the Sarbanes-Oxley Act of 2002). 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
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October 1, 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
Response dated September 6, 2024
File No. 001-41678
Dear Zhi Feng Ang:
We have reviewed your September 6, 2024 response to our comment letter and have the
following comments.
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. Unless we
note otherwise, any references to prior comments are to comments in our August 21, 2024 letter.
Form 20-F for the Fiscal Year Ended December 31, 2023
Item 15. Controls and Procedures, page 61
1.We note your proposed disclosure in response to our prior comment 2 states your internal
controls over financial reporting has been audited by WWC, P.C., an independent
registered public accounting firm. Please include their report in your amendment or
remove this statement. Refer to Item 15(b)(4) and Item 15(c) of Form 20-F.
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-6
2.We reviewed your response to prior comment 4. Please consider revising the line item
description to more accurately indicate the nature of the cash flows.
October 1, 2024
Page 2
Note 28. Income Tax Expense, page F-39
3.We note your response to our prior comment 6. Please expand your disclosure in future
filings to explain the nature of, and reason for, the "non-taxable income" and "unabsorbed
tax losses."
General
4.When filing your amended 20-F, please include the entirety of Parts I, II and III, including
any exhibits that require updating (i.e., certifications pursuant to sections 302 and 906 of
the Sarbanes-Oxley Act of 2002).
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