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      December 31, 2024

      FILED VIA EDGAR

      United States Securities and Exchange Commission

      Division of Corporation Finance

      Office of Real Estate & Construction

      100 F Street, N.E.

      Washington, D.C. 20549

                Attention:

                Ms. Kellie Kim

                Ms. Kristina Marrone

                Re:

                Murano Global Investments Plc

                Form 20-F

                Filed May 1, 2024

                File No. 001-41985

      Ladies and Gentlemen:

      Murano Global Investments Plc (the “Company” or “we”) hereby transmits the Company’s response to the comment letter
        (the “Comment Letter”) received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
        dated December 17, 2024, regarding the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2023 (the “Form 20-F”) filed with the Commission on May 1, 2024. Concurrently with this
        response letter, the Company is publicly filing with the Commission via EDGAR Amendment No. 1 to the Annual Report on Form 20-F/A (“Amendment No. 1”), which has been revised to reflect the Company’s response
        to the Staff’s comment number 2 set forth in the Comment Letter.

      For ease of review, we have set forth below each of the numbered comments in the Comment Letter in bold italics type, followed by the Company’s responses thereto. Unless otherwise indicated,
        capitalized terms used herein have the meanings assigned to them in Amendment No. 1.

      ***

        Note 19. Correction of immaterial errors, page F-48

              1.

                We note the correction of errors related to the classification of non-cash transactions and deferred taxes in previously issued
                  financial statements. Please provide us with a detailed materiality analysis supporting your conclusion that the impact of the errors is not material. In addition, tell us how you complied with the disclosure requirements of paragraph 49
                  of IAS 8.

      Response: The Company respectfully advises the Staff that during the preparation of the financial statements for the year ended December 31, 2023, the Company
          identified certain errors in its prior year combined financial statements, which are summarized as follows:

            1.

              Under the Company’s accounting policy, cash paid for interest recognized as an expense in the statement of profit and loss is classified as a financing cash flow while cash paid on capitalized borrowing costs is classified within cash
                flows from investing activities. For the years ended December 2022 and 2021, the Company appropriately reflected the cash paid on capitalized borrowing costs as cash paid for the acquisition of property, construction in process and
                equipment within investing cash flows. However, such amounts were also erroneously reflected during those periods as a non-cash adjustment to net profit to arrive at cash flows from operating activities, and as interest paid within
                financing activities, thereby overstating cash flows from operating activities and understating cash flows from financing activities in 2022 and 2021 (the “Cash Flow Errors”).

            2.

              During 2022 and 2021, Murano failed to account for deferred taxes related to derivatives that were designated as economic hedges of variable interest debt. The omission of deferred taxes led to misstatements of the combined statements of
                profit and loss and other comprehensive income for the years ended December 31, 2022 and 2021, and the statements of financial position as of December 31, 2022 and 2021 and January 1, 2021 (the “Deferred Tax Errors”).

      The impact of the misstatements on the combined financial statements are summarized as follows:

      Adjustments in the combined statements of financial position

              As of December 31, 2022

              As Previously Reported

              Adjustment

              As Restated

              Deferred tax liabilities

              4,295,874,995

              57,837,596

               4,353,712,591

              Total liabilities

              10,345,727,922

              57,837,596

               10,403,565,518

              Accumulated deficit

              (1,181,000,159)

              (57,837,597)

              (1,238,837,756)

              Total net assets

              8,457,172,581

              (57,837,596)

              8,399,334,985

              As of December 31, 2021

              As Previously Reported

              Adjustment

              As Restated

              Deferred tax liabilities

              2,326,848,915

              (2,384,364)

              2,324,464,551

              Total liabilities

              6,495,730,554

              (2,384,364)

              6,493,346,190

              Accumulated deficit

              (1,485,599,420)

              2,384,364

              (1,483,215,056)

              Total net assets

              4,246,379,239

              2,384,364

              4,248,763,603

              As of January 1, 2021

              As Previously Reported

              Adjustment

              As Restated

              Deferred tax liabilities

              2,171,778,310

              (25,138,382)

              2,146,639,928

              Total liabilities

              5,509,975,376

              (25,138,382)

              5,484,836,994

              Accumulated deficit

              (1,402,845,011)

              25,138,382

              (1,377,706,629)

              Total net assets

              4,199,851,772

              25,138,382

              4,224,990,154

      Adjustments in the combined statements of profit and loss and other comprehensive income

              Year Ended December 31, 2022

              As Previously Reported

              Adjustment

              As Restated

              Income taxes

              (170,487,446)

              (60,221,961)

              (230,709,407)

              Net profit

              304,599,261

              (60,221,961)

              244,377,300

              Total comprehensive income

              4,509,138,666

              (60,221,961)

               4,448,916,705

              Year Ended December 31, 2021

              As Previously Reported

              Adjustment

              As Restated

              Income taxes

              (83,104,963)

              (22,754,018)

              (105,858,981)

              Net profit

              (82,754,409)

              (22,754,018)

              (105,508,427)

              Total comprehensive income

              85,197,957

              (22,754,018)

              62,443,939

      Adjustments in the combined statements of cash flows

              Year Ended December 31, 2022

              As Previously Reported

              Adjustment

              As Restated

              Interest expense

              328,367,127

              (241,931,148)

              86,435,979

              Net cash flows used in operating activities

              (33,580,241)

              (241,931,148)

              (275,511,389)

              Interest paid

              (286,996,622)

              241,931,148

              (45,065,474)

              Net cash flows from financing activities

              1,528,421,985

              241,931,148

              1,770,353,133

              Year Ended December 31, 2021

              As Previously Reported

              Adjustment

              As Restated

              Interest expense

              153,401,639

              (102,952,238)

              50,449,401

              Net cash flows used in operating activities

              (81,026,744)

              (102,952,238)

              (183,978,982)

              Interest paid

              (141,114,065)

              102,952,238

              (38,161,827)

              Net cash flows from financing activities

              732,867,795

              102,952,238

              835,820,033

      Management’s assessment of materiality included a detailed analysis of both quantitative and qualitative factors and is summarized below.

      Quantitative analysis

      In assessing the quantitative magnitude of the errors, management notes that although pre-tax income is typically the starting point for a quantitative measure of materiality, it is not deemed to be the metric that
        is most relevant to the users of the Company’s financial statements. This is because, until the end of 2022, all projects were in the construction phase and the transactions that had a significant impact on the results of 2022 and 2021 were not
        directly attributable to the revenue-generating operations of the Company.

      Accordingly, the Company determined 1% of total assets as the measurement basis to determine the Company’s materiality because it reflects the investments made by the Company to establish the hotels and other real
        estate investments that will form the basis of the Company’s main activities.

      Internal materiality in Mexican pesos for the years ended December 31, 2023, 2022 and 2021, was $194,309,429, $188,029,005 and $107,421,098, respectively. Based on these measures, the impacts of the Cash Flow Errors
        exceed the quantitative thresholds while the impacts of the Deferred Tax Errors on the statements of financial position and profit and loss and other comprehensive income are below the quantitative thresholds.

      Qualitative analysis

      Management’s analysis of qualitative factors is summarized as follows:

            1)

              Whether the misstatement arises from an item capable of being measured with precision or whether it arises from an estimate and, if so, the degree of imprecision inherent in the estimate.

      Analysis: Capitalized borrowing costs were calculated with precision, based on interest
          rates and balances of qualifying assets.

      The misstatements to the deferred tax liability and related expense can similarly be calculated with precision identifying the temporary difference and applying appropriate income tax rates.

            2)

              Whether the misstatement masks a change in earnings or other trends.

      Analysis: No. Due to the Company’s focus on construction and development activities in 2022
          and 2021, the Company realized substantial net cash outflows from operating activities and inflows from proceeds from financing arrangements. The misstatements therefore did not have the effect of masking those trends as the previously reported
          and restated balances reflected the same nature of the cash flows.

      The Company also does not believe the adjustments mask any material changes or trends to net profit during 2022 or 2021. This is because during 2022 and 2021, the Company had not yet generated
        sufficient revenues to achieve an established operational track record.

      Nonetheless, the Company reported other key business and financial metrics, in filings on Form F-4/A filed on February 15, 2024, and in the Company’s annual report on Form 20-F filed on May 1, 2024
        for which the misstated accounts are only used in the determination of non-IFRS performance measures including EBITDA and Adjusted EBITDA. None of the adjustments required to correct the misstatements affect the calculations of these non-IFRS
        measures.

            3)

              Whether the misstatement hides a failure to meet the consensus expectations of analysts for the company.

      Analysis: No. There were no consensus expectations of analysts regarding measures affected
          by the misstatements.

            4)

              Whether the misstatement turns a loss into income or vice versa.

      Analysis: No. The corrections to the misstatements did not change the previously reported
          net operating cash flows or financing cash flows from positive to negative or vice versa.

      Similarly, the misstatements do not turn the net profit into net losses or vice versa for the years ended December 31, 2022 and 2021.

            5)

              Whether the misstatement relates to a segment or other portion of the registrant's business that has been identified as playing a significant role in the registrant's operations or profitability.

      Analysis: No, given that the misstatements relate to the Company’s one and only reportable
          segment, which generated little or no revenues during 2022 or 2021.

            6)

              Whether the misstatement affects the registrant's compliance with regulatory requirements.

      Analysis: No. The Company’s compliance with regulatory requirements was not affected by the
          misstatements.

            7)

              Whether the mistake affects the registrant's compliance with loan covenants or other contractual requirements.

      Analysis: No. The Company’s compliance or failure to comply with loan covenants or other
          contractual requirements was not affected by the misstatements.

            8)

              Whether the misstatement has the effect of increasing management compensation, for example, by satisfying requirements for the granting of bonuses or other forms of incentive compensation.

      Analysis: No. Management’s compensation was not affected by the misstatements.

            9)

              Whether the misstatement involves the concealment of an unlawful transaction.

      Analysis: No. The misstatements do not conceal illegal or unauthorized transactions.

      To further analyze the materiality of the errors, the Company has analyzed the misstatements in light of guidance surrounding the definition of materiality and the impact on the decision-making of the primary users
        of the combined financial statements set forth in paragraph 7 of IAS 1 as follows:

            1)

              Would the correction of the error significantly affect Murano's outlook?

      Analysis: Although the Company’s cash flows are also discussed and analyzed in the
          Management's Discussion and Analysis of Financial Condition and Results of Operations section of the Company’s regulatory filings, such disclosures do not specifically mention the period-to-period changes of cash paid for interest or borrowing
          costs.

      The Company also considered the impacts of the misstatements on management’s accounting and disclosures related to the Company’s ability to continue as a going concern. Both the 2022 financial
        statements filed in the Company’s registration statement on Form F-4/A on February 15, 2024, and the 2023 financial statements filed in the Company’s annual report on Form 20-F on May 1, 2024, disclose material uncertainties giving rise to
        substantial doubt about the Company’s ability to continue as a going concern. In addition, the audit reports on the aforementioned financial statements include explanatory paragraphs related to the going concern uncertainties. Based on management’s
        analysis, neither the individual or cumulative effects of the misstatements impact the conclusions or disclosures reached in relation to the going concern uncertainties reported in the financial statements of 2023 or 2022.

      Based on the above, management concludes that the correction of the misstatements is unlikely to significantly affect Murano's outlook. While the correction resulted in adjustments to deferred tax
        balances and the related expense/benefit, it is unlikely to have a material impact on Murano's overall financial position or performance.

            2)

              Who are