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April 17, 2024
Gao Lianquan
Chief Executive Officer
Premium Catering (Holdings) Ltd
6 Woodlands Walk
Singapore 738398
Re:Premium Catering (Holdings) Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 21, 2024
CIK No. 0001998056
Dear Gao Lianquan:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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. Unless we note otherwise, any references to prior comments are to comments in our
March 1, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Risk Factors
As a "controlled company," we are exempt from certain Nasdaq corporate governance
requirements . . ., page 24
1.Please further revise this risk factor to identify the controlling shareholders and disclose
that the controlling shareholders will have the ability to determine all matters requiring
approval by stockholders, as you do in the section captioned "Implications of Being a
'Controlled Company'" on page 15. Additionally, we note your representation here that
you are a controlled company because "one of [y]our shareholders holds more than 50%
of our voting power."

 FirstName LastNameGao Lianquan
 Comapany NamePremium Catering (Holdings) Ltd
 April 17, 2024 Page 2
 FirstName LastName
Gao Lianquan
Premium Catering (Holdings) Ltd
April 17, 2024
Page 2
However, your disclosure on page 15 indicates that there are two controlling
shareholders. Please advise or revise here and elsewhere as appropriate to address this
discrepancy.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Exposure to risks associated with food safety and the food supply chain may subject us to
liability . . ., page 38
2.We note your response to prior comment 6 and reissue it. The disclosure here states that
you are "exposed to risks associated with . . . the food supply chain, which may subject us
to liability claims, damage our reputation and/or affect our relationship with our
customers.” To the extent your business has been materially affected by disruptions to the
food supply chain, please state as much and include a risk factor discussing this risk and
how your business has been affected. In this regard, we note that your response addresses
food safety, but does not address any risks associated with the food supply chain.
Management
Employment Agreements, page 96
3.We note your response to prior comment 11. Please revise the Exhibit Index to comply
with Item 601(a)(2) of Regulation S-K. In this regard, we note that although Exhibit 10.2
is captioned as “Employment Agreement between Mr. Yu Chun Yin and Premium
Catering,” it hyperlinks to the employment agreement with Ms. Zhang Xiao Ying.
Relatedly, please file your employment agreement with Mr. Yu Chun Lin as an exhibit to
the registration statement or tell us why you believe you are not required to do so. Refer to
Item 601(b)(10)(ii) of Regulation S-K.
Notes to Consolidated Financial Statements
Note 3 - Summary of Significant Accounting Policies
(l) Revenue Recognition, page F-10
4.We have reviewed your response to prior comment 15 noting your revenue is recorded net
of goods and services tax. Please provided the disclosures required by ASC 606-10-32-
2A.
General
5.On page Alt-4, please identify the natural person(s) with voting and/or investment control
over the shares held by the entity selling shareholders.

 FirstName LastNameGao Lianquan
 Comapany NamePremium Catering (Holdings) Ltd
 April 17, 2024 Page 3
 FirstName LastName
Gao Lianquan
Premium Catering (Holdings) Ltd
April 17, 2024
Page 3
            Please contact Valeria Franks at 202-551-7705 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Rucha Pandit at 202-551-6022 or Erin Jaskot at 202-551-3442 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Henry Schlueter