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                         Partners

Geoffrey Chan *

Shu Du *

Andrew L. Foster *

Chi T. Steve Kwok *

Haiping Li *

Rory McAlpine ¨

Jonathan B. Stone *

Paloma P. Wang ¨

Friven Yeoh ¨

¨
(Also Admitted in England & Wales)

*
(Also Admitted in New York)

                         Skadden,
Arps, Slate, Meagher & Flom

世達國際律師事務所

42/F,
EDINBURGH TOWER, THE LANDMARK

                         15
QUEEN’S ROAD CENTRAL, HONG KONG

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                         TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

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BRUSSELS

FRANKFURT

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September 17, 2025

Confidential

Mr. Peter McPhun

Mr. Mark Rakip

Ms. Pearlyne Paulemon

Mr. Jeffrey Gabor

Division of Corporation Finance

Office of Real Estate & Construction

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: TGE Value Creative Solutions Corp

Registration Statement on Form S-1

Filed August 18, 2025

File No. 333-289690

Dear Sir/Madam,

On behalf of our client, TGE Value Creative Solutions
Corp, a company organized under the laws of the Cayman Islands (the “Company”), we are hereby submitting to the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter setting forth
the Company’s responses to the comments contained in the Staff’s letter dated September 12, 2025 on the Company’s registration
statement on Form S-1 filed on August 18, 2025 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is filing amendment No. 1 to the Company’s registration statement on Form S-1 (the “Revised Registration
Statement”) and certain exhibits via EDGAR with Commission.

    Securities and Exchange Commission

September 17, 2025

Page 2

The Staff’s comments are repeated below in
bold and are followed by the Company’s responses. The Company has included page references in the Revised Registration Statement
where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings
set forth in the Revised Registration Statement.

Registration Statement on Form S-1 filed
August 18, 2025

Cover Page

 1. We note in the summary dilution table you appear to have calculated the Difference between NTBV and Offering Price in a manner
inconsistent with the Item. Please amend to revise the table to calculate the difference between the offering price and such net tangible
book value per share; refer to Item 1602(a)(4) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on the cover page of the Revised Registration Statement.

 2. Where you first discuss the voting rights of the Class B ordinary shares, please revise to clearly state the different voting rights
of the Class B and Class A ordinary shares, including the continuation of the company in a jurisdiction outside of the Cayman Islands
as you disclose on page 46. Please also revise under the caption “Founder Shares” on page 13 and “Appointment of Directors;
Voting” on page 16.

In response to the Staff’s
comment, the Company has revised the disclosure on the cover page, page 20, page 22, page 59 and page 148 of the Revised Registration
Statement.

 3. When discussing the amount of compensation received or to be received, as required by Item 1602(a)(3) of Regulation S-K, please
include the determination of the number of shares issuable upon conversion of the founder shares under the anti-dilution mechanism and
the monthly payments to the sponsor or an affiliate for office space, utilities, secretarial and administrative support services. Ensure
that you include the amounts of each form of compensation and securities issuance, and whether they may result in a material dilution
of the purchasers’ equity interests. Please also provide a cross-reference to all relevant sections in the prospectus for disclosures
related to compensation, highlighted by prominent type or in another manner, as required by Item 1602(a)(3) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on the cover page of the Revised Registration Statement.

    Securities and Exchange Commission

September 17, 2025

Page 3

 4. We note that you will have 24 months from the closing of this offering, or until such earlier liquidation date, to consummate an
initial business combination. However, we also note your disclosure on page F-8 that you have 24 months from the closing of this offering
(or 27 months from the closing of the Proposed Public Offering if the Company has executed a letter of intent, agreement in principle
or definitive agreement for an initial business combination within 24 months from the closing of the Proposed Public Offering). Please
revise or advise. See Item 1602(a)(1) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on page F-8 of the Revised Registration Statement.

Prospectus Summary, page 1

 5. We note your disclosure on page 7 and elsewhere that members of your management team (including your independent directors) may
directly or indirectly own founder shares and/or private placement units following this offering. Please revise to disclose the persons
who have direct and indirect material interests in the sponsor, as well as the nature and amount of their interests. In addition, please
revise to clarify the identity of the controlling person(s) of the sponsor. See Item 1603(a)(7) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on the cover page, page 1, page 7, page 99 and page 105 of the Revised Registration Statement.

 6. Please revise to state both the amount and nature of compensation and the amount of securities and the price to be paid by each
sponsor, sponsor affiliate and promoter. This information should be provided in tabular format, providing line items for each compensation
item. Please also disclose, outside of the table, “the extent to which” compensation and securities may result in a material
dilution of the purchasers’ equity interests and the anti-dilution adjustment of the founder shares inside the table. Please see
to Item 1602(b)(6) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on page 8 to page 10 of the Revised Registration Statement.

 7. Please revise your summary to describe any actual or potential material conflicts between the sponsor, its affiliates, or promoters,
and purchasers in the offering, including those that may arise in determining whether to pursue a de-SPAC transaction. For example, you
should discuss potential material conflicts relating to compensation, the financial interests of the sponsor, its affiliates and promoters
in completing any de-SPAC transaction within the allotted time, repayment of loans, as well as the fact that the company may pursue a
de-SPAC transaction with a target that is affiliated with the sponsor, its affiliates or promoters. Please see Item 1602(b)(7) and Item
1603(b) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on page 6 to page 10 of the Revised Registration Statement.

    Securities and Exchange Commission

September 17, 2025

Page 4

 8. We note your disclosure here and elsewhere that your management team has led the public offerings of AMTD Group, AMTD IDEA Group
(NYSE: AMTD), AMTD Digital Inc. (NYSE: HKD), and the business combination between TGE and Black Spade Acquisition II Co. If your sponsor,
its affiliates, promoters and management team have experience in organizing or are involved in any other special purpose acquisition companies,
please include the disclosure required by Item 1603(a)(3) of Regulation S-K. For any prior SPAC, please disclose any extensions of the
time to complete the transaction and the level of redemptions in connection therewith, and information concerning any completed business
combinations, including the financing needed for the transactions and the level of redemptions. Please see Item 1603(a)(3) of Regulation
S-K.

The Company respectfully acknowledges
the Staff’s comment and advises the Staff that, except in relation to the Company, its sponsor, its affiliates, promoters and management
team do not have any experience in organizing and are not involved in any other special purpose acquisition companies. The Company has
also revised the disclosure on page 7 and page 106 of the Revised Registration Statement.

 9. Please explain the material roles and responsibilities of AMTD Group, if any, in directing and managing the company’s activities.
We note disclosure on pages 1 and 93 given your affiliation with AMTD Group you intend to leverage AMTD’s full suite of capabilities
— including its operational track record, investment expertise, and long-term capital base, and disclosure on page 122 regarding
potential conflicts of interest. If you have any agreements with AMTD Group or other TGE entities, please disclose material terms and
file them as exhibits. In addition, if AMTD Group has any direct or indirect material interest in the sponsor, please disclose the nature
and amount thereof. Lastly, please include similar revisions in the business section. Refer to Items 1603(a)(4) and 1603(a)(7) of Regulation
S-K.

The Company respectfully acknowledges
the Staff’s comment and advises the Staff that AMTD Group has no material roles or responsibilities in directing or managing the
Company’s activities and the Company does not have any agreements with AMTD Group or other TGE entities except those entered or
to be entered into with the Company’s sponsor and set forth in the Revised Registration Statement. The Company has revised cover
page, page 1, page 7, page 99 and page 105 of the Revised Registration Statement to disclose AMTD Group’s direct or indirect material
interest in the sponsor.

    Securities and Exchange Commission

September 17, 2025

Page 5

 10. Please disclose your plans if you do not consummate a de-SPAC transaction within 24 months, including whether there are any limitations
on the number of extensions, including the number of times, and the consequences to the SPAC sponsor of not completing an extension of
this time period. Please also disclose whether security holders will have voting or redemption rights with respect to an extension. See
Item 1602(b)(4) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on page 8 of the Revised Registration Statement.

 11. You state that your sponsor is an affiliate of The Generation Essentials Group. Please clarify your defined terms to establish
what entity you refer to throughout your prospectus as “The Generation Essentials Group.” In this regard, we note your disclosures
on page 119. To the extent applicable, please also revise your disclosures in the Summary, and elsewhere in your prospectus as appropriate,
to provide appropriate disclosures regarding The Generation Essentials Group, such as expanded disclosures regarding its roles and responsibilities,
any compensation payable to it, and any actual or potential conflicts that may arise from your sponsor’s connection with The Generation
Essentials Group. See, for example, Items 1602(b)(6), 1602(b)(7), 1603(a)(3), and 1603(a)(4) of Regulation S-K.

In response to the Staff’s
comment, the Company has revised the disclosure on page 1, page 6, page 7, page 99, page 104, page 105 and page 134 of the Revised Registration
Statement.

 12. Disclose the potential conflicts of interest arising from the ability to pursue an Affiliated Joint Acquisition opportunity.

In response to the Staff’s
comment, the Company has revised the disclosure on page 8, page 62, page 104 and page 136 of the Revised Registration Statement.

Founder shares, page 13

 13. We note your disclosure that in addition to your initial shareholders’ founder shares, you would need 5,750,001, or 25% (assuming
only the minimum number of shares representing a quorum are voted and the overallotment option is not exercised). Please explain to us
this calculation, as we note, for example, that there are 5,750,000 initial founder shares. In addition, please revise your disclosure
to clarify the amount of public shares that would need to be voted in favor of an initial business combination if only the number of shares
representing a quorum are voted.

In response to the Staff’s
comment, the Company has revised the disclosure on page 20, page 23, page 30, page 40, page 117 and page 147 of the Revised Registration
Statement.

    Securities and Exchange Commission

September 17, 2025

Page 6

Anticipated expenses and funding sources, page 19

 14. Please revise this section or include a new section within the Summary under an appropriate subcaption to provide a more comprehensive
discussion regarding whether you have any plans to seek additional financing and how such financings may impact unaffiliated security
holders, as required by Item1602(b)(5) of Regulation S-K. In this regard, we note your disclosure on page 61 that you intend to target
businesses with enterprise values that are greater than the net proceeds of this offering and the sale of the private placement warrants.

In response to the Staff’s
comment, the Company has revised the disclosure on page 13 of the Revised Registration Statement.

Risk Factors, page 31

 15. Please include a risk factor that describes the potential material effect on your shareholders of the stock buyback excise tax
enacted as part of the Inflation Reduction Act in August 2022. If applicable, include in your disclosure that the excise tax could reduce
the trust account funds available to pay redemptions or that are available to the combined company following a de-SPAC transaction. Also
describe, if applicable, the risk that if existing SPAC investors elect to redeem their shares such that their redemptions would subject
the SPAC to the stock buyback excise tax, the remaining shareholders that did not elect to redeem may economically bear the impact of
the excise tax.

The Company respectfully acknowledges
the Staff’s comment and advises the Staff that as the excise tax enacted as part of the Inflation Reduction Act is not applicable
to the Company, no relevant disclosure has been added in the Revised Registration Statement.

We may engage our underwriter or one
of their respective affiliates to provide additional services..., page 55

 16. Please expand this risk factor to also discuss the conflicts of interest risks arising from the underwriters’ ownership of the
private placement warrants.

In response to the Staff’s
comment, the Company has revised the disclosure on page 63 and page 64 of the Revised Registration Statement.

    Securities and Exchange Commission

September 17, 2025

Page 7

Our warrant agreement will designate...,
page 64

 17. We note your disclosure on page 64 that the exclusive forum provisions of the warrant agreement will not apply to suits brought
to enforce any liability or duty created by the Securities Act, the Exchange Act or any other claim for which the federal district courts
of the United States of America are the sole and exclusive forum. However, we also note your disclosure on page 139 that the exclusive
forum provision applies to claims under the Securities Act. Please revise to reconcile the inconsistency or advise.

In response to the Staff’s
comment, the Company has revised the disclosure on page 154 of the Revised Registration Statement.

Dilution, page 82

 18. We note you did not provide a tabular presentation of dilution to public shareholders at quartile intervals based on the percentages
of the maximum redemption threshol