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SKK
Holdings Limited

27
First Lok Yang

Singapore
629735

February
6, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Babette Cooper

    Re:
    SKK Holdings Limited

    Registration Statement
    on Form F-1

    File No. 333-276744

Ladies
and Gentlemen:

We
are in receipt of your comment letter to our Form F-1 Registration Statement that was filed on January 29, 2024 (the “Registration
Statement”). We have restated your comments below and included our reply and are submitting Amendment No. 1 to the Registration
Statement simultaneously with this correspondence.

Cover
Page

1. We
                                            note your response to prior comment 1. Please disclose on the cover page and under Risk Factors
                                            on page 26, that selling shareholders are also offering 1,647,999 shares for resale.

We
have revised our disclosure on the cover page and the Risk Factors on page 26 to include the resale shares, as requested.

Exhibit
21.1

2. We
                                            note the consent from your auditors dated January 29, 2024, that refers to the auditor’s
                                            report dated September 30, 2023. Please revise to include a consent that refers to the actual
                                            auditor’s report date of September 30, 2023, except for Notes 1 and 11, as to which
                                            the date is January 8, 2024.

We
have filed a consent of auditors as Exhibit 21.1 that correctly refers to the auditor’s report date of September 30, 2023,
except for Notes 1 and 11, as to which the date is January 8, 2024, as requested.

Exhibit
Index

3. 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. Also describe these loans under Related Party Transactions.

We
have filed the debt agreements with Ms. Liao as Exhibit 10.1, as requested and added disclosure to describe these loans under
Related Party Transactions on page 97, as requested.

4. Please
                                            file as exhibits any material agreements relating to your bank borrowings. See Item 601(b)(10)(i)(A)
                                            of Regulation S-K.

We
have filed the material agreement relating to our bank borrowings as Exhibit 10.2, as requested.

5. We
                                            note your statement on page 61 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.

We
have filed the consent of Frost & Sullivan as Exhibit 21.3.

Please
notify R. Joilene Wood of any questions regarding the submission at 415-305-4651 or jwood@troygould.com.

    Sincerely,

    SKK Holdings Limited

    /s/ Koon
    Kiat Sze

    Koon Kiat Sze

    Chief Executive Officer

    cc:
    David L. Ficksman

    R. Joilene Wood