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June 2, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted May 25, 2023
CIK No. 0001963439
Dear Emilio Cañavate:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, 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 comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted May 25, 2023
Related Party Transactions, page 67
1.Item 7.B. of Form 20-F requires that you include information since the beginning of the
company’s preceding three financial years up to the date of the document. Please revise.
Consolidated Financial Statements
Note 12 - Share Capital, page F-20
2.We note in February 2023 the Company approved a forward stock split on a 20-for-1 basis
that increased your issued and outstanding share capital from 2,504,285 ordinary shares to
50,085,700 ordinary shares. We also note during December 2022 you issued 50,000,000

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 June 2, 2023 Page 2
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
June 2, 2023
Page 2
shares (2,500,000 shares on a pre-stock split basis) of common stock for proceeds of
€2,500,000, to your parent company, who is also your sole shareholder. Given the
impact of the share issuance during December 2022 and the forward stock split in
February 2023 relative to the Company’s historical capitalization, neither of which
impacted the ownership of the Company, please explain to us how and why you
determined it would not be more appropriate to also retro-actively reflect the share
issuance that occurred during December 2022 in determining the number of shares
outstanding used to calculate earnings per share during each period presented, similar to
the treatment of the forward stock split. Please specifically address your consideration of
paragraphs 21, 26, 28, and 64 of IAS 33. In this regard, it appears the December share
issuance may lack substance and the current earnings per share disclosures are not
indicative of the actual capitalization of the Company going forward.
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        Louis A. Bevilacqua