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October 17, 2023
Koon Kiat Sze
Chief Executive Officer
SKK Holdings Limited
27 First Lok Yang Road
Singapore 629735
Re:SKK Holdings Limited
Draft Registration Statement on Form F-1
Submitted September 20, 2023
CIK No. 0001991261
Dear Koon Kiat Sze:
            We have reviewed your draft registration statement and have the following comments.
            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 a 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 this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
DRS on Form F-1 Submitted September 20, 2023
General
1.Please revise your website URL in the filing, as the current URL you disclose does not
exist.
Financial Information in United States Dollars, page 2
2.We note you disclose your reporting currency is the Singapore Dollar and that this
prospectus contains translations of certain foreign currency amounts into United States
Dollars for the convenience of the reader.  However, disclosure in other parts of your
filing, including in Note 2 to your consolidated financial statements on page 126, indicates
the reporting currency of the company is the United States Dollar (“US$”) and the
accompanying consolidated financial statements have been expressed in US$.  Please
advise.  In addition, please explain to us why you translate financial information included
in your Results of Operations Data and Balance Sheet Data tables on page 38

 FirstName LastNameKoon Kiat  Sze
 Comapany NameSKK Holdings Limited
 October 17, 2023 Page 2
 FirstName LastName
Koon Kiat  Sze
SKK Holdings Limited
October 17, 2023
Page 2
into Singapore Dollars when your reporting currency is the US$ for your consolidated
financial statements.
Prospectus Summary, page 8
3.Please disclose here and in the applicable risk factors the number of shares the selling
shareholders are offering for resale.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
39
4.Please revise to discuss any known trends, uncertainties, demands, commitments, or
events that are reasonably likely to have a material effect on the company’s net sales or
revenues, income from continuing operations, profitability, liquidity or capital resources,
or that would cause reported financial information not necessarily to be indicative of
future operating results or financial condition. For example, to the extent known, expand
your MD&A to discuss the impact of economic conditions, including inflation, supply
chain disruptions, and labor shortages. Refer to Item 5.D. of Form 20-F.
Business, page 63
5.We note your disclosure on page 63 that at December 31, 2022 you had nine civil
engineering services projects in progress and, as of the date of the prospectus, you have
successfully tendered/quoted for five additional new civil engineering services projects.
Please describe these projects in greater detail, such as the type of project, the material
terms of the agreements relating to these projects, the anticipated completion dates, and
any material risks associated with these projects.
Principal and Selling Shareholders, page 91
6.We note that most of the selling shareholders in the primary offering are also selling in the
resale offering.  Please also disclose the number of shares owned by the beneficial owners
after the resale offering.
7.Please disclose the addresses of the entities that are selling shareholders.
Related Party Transactions, page 93
8.Please provide the disclosure required by Item 7.B of Form 20-F for the preceding three
financial years up to the date of the prospectus, including the names of the related parties,
the amount involved and the material terms of the transactions.  Also disclose the
securities issuances to the related parties that you describe on page 104 and the amounts
due to related parties that you describe on page 134.

 FirstName LastNameKoon Kiat  Sze
 Comapany NameSKK Holdings Limited
 October 17, 2023 Page 3
 FirstName LastName
Koon Kiat  Sze
SKK Holdings Limited
October 17, 2023
Page 3
Consolidated Balance Sheets, page 120
9.We note the contract assets reported in your consolidated balance sheets.  Please revise to
provide the disclosures required for contract balances, in accordance with ASC 606-10-
50-8 to 10; or, tell us why this does not apply to you.
Consolidated Statements of Operations and Comprehensive Income, page 121
10.It appears cost of revenue does not include any depreciation or amortization expense and
you present a subtotal for gross profit.  Please tell us how your presentation complies with
SAB Topic 11.B.  In this regard, if depreciation or amortization is not allocated to cost of
revenue, you should remove the gross profit subtotal from your statements of operations
and re-label the cost of revenue line item to indicate that it excludes depreciation and
amortization. As appropriate, please also revise your cost of revenue significant
accounting policy disclosure to clarify whether depreciation and amortization expense is
included.
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page 127
11.We note your disclosure stating you recognize revenue by estimating total costs under the
input method.  You state that contract costs consist of both direct and indirect costs.
Please clarify the nature of the contract costs included in your calculations and tell us why
you believe your input methodology properly depicts your performance in transferring
control of the services promised.  Reference is made to ASC 606-10-55-20 and 21.
12.We note you disclose in Note 3 - Disaggregation of Revenue that you have revenue
recognized at a point in time.  Please revise your revenue recognition policy to discuss
these revenue arrangements, including the nature of these arrangements, description of
goods or services provided, key terms, and the specific performance obligations.  In
addition, please discuss the significant judgments made in evaluating when a customer
obtains control of promised goods or services under these arrangements.  Refer to ASC
606-10-25-30 and 606-10-50-19.
Signatures, page II-5
13.Please revise the titles to reflect that the filing has been signed by individuals in their
applicable capacities as principal executive officer, principal financial officer, controller
or principal accounting officer and director. See the signature requirements in Form F-1.
Exhibit Index, page II-4
14.We note that you intend to use a portion of the net proceeds to repay interest-free loans
from Ms. Liao. Please file as an exhibit your debt agreements with Ms. Liao. See Item
601(b)(10)(ii)(A) of Regulation S-K.

 FirstName LastNameKoon Kiat  Sze
 Comapany NameSKK Holdings Limited
 October 17, 2023 Page 4
 FirstName LastName
Koon Kiat  Sze
SKK Holdings Limited
October 17, 2023
Page 4
15.We note your statement on page 57 that you have presented information and data from an
industry report commissioned by you from Frost & Sullivan. Please file a consent as an
exhibit to the registration statement pursuant to Rule 436 of the Securities Act.
16.Please file as exhibits any material agreements relating to your bank borrowings.  See
Item 601(b)(10)(i)(A) of Regulation S-K.
Resale Shareholders, page Alt-1
17.Please describe the material terms of the transactions pursuant to which the selling
shareholders acquired the shares being offered.
            Please contact Babette Cooper at 202-551-3396 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       David L. Ficksman