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March 6, 2023
Siyu Yang
Chief Executive Officer
Baiya International Group Inc.
Yifang Capital Industrial Park
No. 33 Pingshan Industrial Road, Building A, 16F
Tangxia, Dongguan, Guangdong, China
Re:Baiya International Group Inc.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted February 14, 2023
CIK No. 0001944712
Dear Siyu Yang:
            We have reviewed your amended draft registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to our comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 Submitted February 14, 2023
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies and Estimates
Revenue Recognition, page F-18
1.You disclose your Gongwuyuan Platform connects HR and labor resource companies with
business enterprises allowing matching of job-seeking blue-collar workers with the labor
recruitment needs of businesses and provides employment matching of blue-
collar workers through HR service companies with business enterprises and institutions.
It appears from these disclosures you serve as an intermediary between employing
companies and third-party labor service providers to arrange to meet their respective

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needs.  For both of your entrusted recruitment and project outsourcing services you state
you recognize revenue gross as a principal.  To help us better understand the basis for
your accounting treatment, please address the following for each of these services, unless
otherwise indicated.

1.Provide us with a typical agreement with each of the employing companies and
third-party labor service providers.
2.Explain to us in detail how you control the workers provided by third-party labor
service providers before their service is transferred to employing companies.  In
particular, tell us (i) whether workers provided become your employees, and if so,
the basis for this determination, and (ii) the party responsible for employee
administration for workers provided, including (a) payment of wages/salaries to
workers, (b) withholding, collection and remittance of associated
employer/employee payroll taxes, (c) benefits (including paid time off) provided to
workers, (d) any worker related insurances and (e) injuries incurred by workers on
the job.  In regard to this overall item, we note your disclosure your cost of revenues
for each service primarily consists of the referral or service fees and out sourcing
fees paid to labor-provider companies.  In regard to (i), under "Employees" on page
117 we note only employees for labor dispatch workers.  In regard to (ii), we note
your disclosure on page 27 "Our Gongwuyuan Platform rely on third parties
payment providers ... to support relevant payment needs such as wage payments
from Employing Company to workers."  If your control is under some other basis,
explain that basis in detail and why it supports control by you.
3.We note the risk factor on page 28 stating the PRC operating companies sometimes
outsource labor assignments to HR service companies to recruit the required
workers in completing their relevant worker recruitment or labor assignments for
customers.  Explain to us how this affects your control of the workers provided to
employing companies.
4.Tell us the party that selects workers for employing companies and how this is
factored in your assessment that you have discretion in fulfilling your performance
obligation and control of the labor provided.  In regard to entrusted recruitment, it
appears from your disclosure on page F-20 employing companies select the labor
candidates provided by third-party labor providers and not you.
5.In regard to entrusted recruitment you disclose on page F-20 you do not have any
obligation to pay third-party labor companies for labor candidates not selected by
employing companies.  Explain to us the impact of this on your determination of
whether you have inventory risk for labor provided.
6.Tell us the party that determines the service fee you receive from employing
companies and how the fee is determined.  Specifically in regard to entrusted
recruitment, the response to comment 13 in your letter dated December 27, 2022
states you have discretion establishing the transaction price with employing
companies.  However, in the same response you state employing companies
normally specify in their Overall Work Arrangement the pay rate to the worker as

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well as the service payout rate to you in placing workers for entrusted recruitment
services.  Explain to us your consideration of this in your determination that you
have pricing discretion for entrusted recruitment, and how this impacts your
assessment of your control of labor.
7.Tell us the party that determines the amount you pay third-party labor providers and
how this amount is determined.
8.Tell us when you pay third-party labor providers and the material terms associated
with payments, in particular any contingent provisions.
            You may contact Nasreen Mohammed at 202-551-3773 or Doug Jones at 202-551-
3309 if you have questions regarding comments on the financial statements and related
matters.  Please contact Scott Anderegg at 202-551-3342 or Dietrich King at 202-551-8071 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services