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Turbo Energy, S.A.

Plaza de América 2, 4AB

Valencia, Spain 46004

December 12, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Turbo Energy, S.A.

    Registration Statement on Form F-3

    File No. 333-291470

Ladies and Gentlemen:

Pursuant to Rules 460 and
461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Turbo Energy, S.A.
(the “Company”) respectfully requests that the effective date of the registration statement referred to above (the
“Registration Statement”) be accelerated so that it will become effective at 4:00 p.m., Eastern Time, on Tuesday, December
16, 2025, or as soon thereafter as possible. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities
under the Act.

Once the Registration Statement
is effective, please orally confirm the event with our counsel, Satin and Lee Law P.C. by calling Elliot Lee, Esq. at (516) 421-6103.
We also respectfully request that a copy of the written order from the Securities and Exchange Commission verifying the effective time
and date of the Registration Statement be sent to our counsel, Satin and Lee Law P.C., Attention: Elliot Lee, Esq., by facsimile to (516)
421-6105 or email at elee@satinandlee.com.

If you have any questions
regarding this request, please contact Elliot Lee, Esq. of Satin and Lee Law P.C. at (516) 421-6103.

    Very Truly Yours,

    By:
    /s/ Mariano Soria

    Name:
    Mariano Soria

    Title:
    Chief Executive Officer

    cc:
    Elliot Lee, Esq., Satin and Lee Law P.C.

December 16, 2024
Alejandro Moragues
Chief Financial Officer
Turbo Energy, S.A.
Street Isabel la Católica, 8, Door 51
Valencia, Spain 46004
Re:Turbo Energy, S.A.
Form 20-F for the Year Ended December 31, 2023
File No. 001-41813
Dear Alejandro Moragues:
            We have completed our review of your filings. We remind you that the company and
its management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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Turbo Energy, S.A.

Street Isabel la Católica, 8, Door 51

Valencia, Spain 46004

December 13, 2024

Via EDGAR and E-Mail

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E. Washington, D.C. 20549

Attention: Melissa Gilmore and Kevin Woody

    Re:

    Turbo Energy, S.A.

    Form 20-F for the Year Ended December 31, 2023

    File No. 001-41813

Ladies and Gentlemen:

We hereby submit the responses of Turbo Energy,
S.A. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) set forth in the Staff’s letter, dated December 3, 2024, providing the Staff’s
comments with respect to the above-referenced Company’s annual report on Form 20-F, for the fiscal year ended December 31, 2023
(the “Form 20-F”). Concurrently with the submission of this letter, the Company is submitting its Amendment No. 1 to
the Form 20-F (the “Amendment No. 1”) together with certain exhibits via EDGAR with the Commission.

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company.

Form 20-F for the Year Ended December 31, 2023

Item 15. Controls and Procedures

Evaluation of Disclosure Controls and Procedures,
page 92

    1.
    Based on your disclosures, it appears that your chief executive officer and chief financial officer concluded that, as of December 31, 2023, your disclosure controls and procedures (“DCP”) were determined to be effective. However, we note that your assessment of internal control over financial reporting (“ICFR”) was not effective due to the material weaknesses described therein. To the extent that ICFR has been determined to be not effective due to the material weakness identified, we would expect your DCP also to be not effective due to the substantial overlap of controls. Refer to SEC Release No. 33-8238, Section II.D. Please revise to ensure consistent conclusions for both DCP and ICFR are presented.

RESPONSE: In response to the Staff’s
comments, we respectfully advise the Staff that, upon review, we determined the inconsistency was due to an inadvertent typographical
error, which has been corrected in Amendment No. 1. Specifically, our Chief Executive Officer and Chief Financial Officer concluded that
our Company’s ICFR was effective as of December 31, 2023, and the conclusion regarding DCP is now consistent with this assessment.

Management’s Annual Report on Internal Control
Over Financial Reporting, page 93

    2.
    We note your disclosure that based on your evaluation and as a result of the material weakness discussed within, your chief executive officer and chief financial officer concluded that the Company’s internal control over financial reporting was effective as of December 31, 2023 due to the existence of the disclosed significant deficiencies. Please correct your disclosure as it appears the conclusion should state “not effective” instead of “effective” in your conclusion. Please revise or advise us accordingly.

RESPONSE: In response to the Staff’s
comments, we respectfully advise the Staff that, upon review, we determined the inconsistency was due to an inadvertent typographical
error. There were no material weaknesses in the Company’s ICFR as of December 31, 2023. We have corrected our disclosure in Amendment
No. 1.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +34 961 196 250 or
Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    TURBO ENERGY, S.A.

    By:
    /s/ Mariano Soria

    Name:
    Mariano Soria

    Title:
    Chief Executive Officer and Director

    cc: Louis A. Bevilacqua, Esq.

December 3, 2024
Alejandro Moragues
Chief Financial Officer
Turbo Energy, S.A.
Street Isabel la Católica, 8, Door 51
Valencia, Spain 46004
Re:Turbo Energy, S.A.
Form 20-F for the Year Ended December 31, 2023
File No. 001-41813
Dear Alejandro Moragues:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Year Ended December 31, 2023
Item 15. Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 92
1.Based on your disclosures, it appears that your chief executive officer and chief
financial officer concluded that, as of December 31, 2023, your disclosure controls
and procedures ("DCP") were determined to be effective. However, we note that your
assessment of internal control over financial reporting ("ICFR") was not effective due
to the material weaknesses described therein. To the extent that ICFR has been
determined to be not effective due to the material weakness identified, we would
expect your DCP also to be not effective due to the substantial overlap of controls.
Refer to SEC Release No. 33-8238, Section II.D. Please revise to ensure consistent
conclusions for both DCP and ICFR are presented.
Management's Annual Report on Internal Control Over Financial Reporting, page 93
We note your disclosure that based on your evaluation and as a result of the material
weakness discussed within, your chief executive officer and chief financial officer 2.

December 3, 2024
Page 2
concluded that the Company’s internal control over financial reporting was effective
as of December 31, 2023 due to the existence of the disclosed significant
deficiencies.  Please correct your disclosure as it appears the conclusion should state
"not effective" instead of "effective" in your conclusion.  Please revise or advise us
accordingly.
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
            Please contact Melissa Gilmore at 202-551-3777 or Kevin Woody at 202-551-3629
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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TURBO ENERGY, S.A.

Street Isabel la Católica,
8, Door 51

Valencia, Spain 46004

September 19, 2023

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

 Re: TURBO ENERGY, S.A.

Registration Statement
on Form F-1

File No.
333- 273198 (the “Registration Statement”)

Ladies and Gentlemen:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 5:00 p.m. (Eastern Time) on September 21,
2023, or as soon thereafter as practicable.

Please
contact Louis A. Bevilacqua, Esq. of Bevilacqua PLLC, U.S. counsel of the Company, at (202) 869-0888, ext. 100. to provide notice of effectiveness,
or if you have any questions or concerns regarding the foregoing.

    Very truly yours,

    Turbo Energy, S.A.

    By:
    /s/ Enrique Selva Bellvis

    Name:
    Enrique Selva Bellvis

    Title:
    Chief Executive Officer

cc: Louis A. Bevilacqua, Esq.

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September 19, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re: Registration Statement on Form F-1, as amended

    File No. 333-273198

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), we, the underwriter (the “Underwriter”), hereby join in the request
of Turbo Energy, S.A. (the “Registrant”), for the acceleration of the effective date of the Registrant’s Registration
Statement on Form F-1 (File No. 333-273198) (as amended, the “Registration Statement”), relating to a public offering
of the Registrant’s American depositary shares of the Registrant so that the Registration Statement may be declared effective on
September 21, 2023, at 5.00 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned, as the Underwriter, confirms that
it is aware of its obligations under the Securities Act.

Pursuant to Rule 460 under the Securities Act, please
be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate in the distribution
of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution
of the preliminary prospectus.

The undersigned confirms that it has complied with
and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with or
will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced
issue.

    Very truly yours,

    BOUSTEAD SECURITIES LLC

    /s/ Keith Moore

    Name: Keith Moore

    Title: Chief Executive Officer

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Turbo Energy, S.A.

Street Isabel la Católica,
8, Door 51,

Valencia, Spain 46004

September 15, 2023

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Eiko Yaoita Pyles

Anne McConnell

Sarah Sidwell

Erin Purnell

Re: Turbo
                                            Energy, S.A.

Amendment No. 2 to
Registration Statement on Form F-1

Filed August 28, 2023

File No. 333-273198

Ladies and Gentlemen:

We hereby submit the responses
of Turbo Energy, S.A. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated September 5, 2023, providing
the Staff’s comments with respect to the Company’s Amendment No. 2 to Registration Statement on Form F-1 Filed on August
28, 2023. Concurrently with the submission of this letter, the Company is submitting the Amendment No.3 to the Registration Statement
(the “Amendment No. 3”) on Form F-1 together with certain exhibits via EDGAR with the Commission.

For the convenience of
the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context
indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a
consolidated basis.

Registration Statement on Form F-1 filed
on August 28, 2023

Exhibits

 1. We note that Titan Partners Group
                                            has joined as an underwriter to this transaction and will be the representative for the underwriters.
                                            However, the form of Underwriting Agreement references only Boustead Securities as sole underwriter
                                            and representative. Please provide the Underwriting Agreement with Titan Partners Group LLC.

RESPONSE: In response to the
Staff’s comments, we have revised the form of Underwriting Agreement to reflect that both Titan Partners Group and Sutter Securities,
Inc. have joined as underwriters to this transaction. Boustead Securities, LLC will be the representative for the underwriters. We have
made conforming changes in the Amendment No.3 and the form of Underwriting Agreement.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +34 961 196 250 or
Louis Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    TURBO ENERGY, S.A.

    By:
    /s/ Enrique Selva Bellvis

    Name:
    Enrique Selva Bellvis

    Title:
    Chief Executive Officer

cc: Louis A. Bevilacqua,
Esq., Bevilacqua PLLC

United States securities and exchange commission logo
September 5, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Amendment No. 2 to Registration Statement on Form F-1
Filed August 28, 2023
File No. 333-273198
Dear Emilio Cañavate:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 4, 2023 letter.
Registration Statement on Form F-1 filed on August 28, 2023
Exhibits
1.We note that Titan Partners Group has joined as an underwriter to this transaction and will
be the representative for the underwriters. However, the form of Underwriting Agreement
references only Boustead Securities as sole underwriter and representative. Please provide
the Underwriting Agreement with Titan Partners Group LLC.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 September 5, 2023 Page 2
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
September 5, 2023
Page 2
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        Louis A. Bevilacqua

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Turbo Energy, S.A.

Street Isabel la Católica, 8, Door 51,

Valencia, Spain 46004

August 28, 2023

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Eiko Yaoita Pyles

Anne McConnell

Sarah Sidwell

Erin Purnell

 Re: Turbo Energy, S.A.

Amendment No. 1 to Registration
Statement on Form F-1

Filed July 26, 2023

File No. 333-273198

Ladies and Gentlemen:

We hereby submit the responses of Turbo
Energy, S.A. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated August 4, 2023, providing the Staff’s
comments with respect to the Company’s Amendment No. 1 to Registration Statement on Form F-1 Filed on July 26, 2023. Concurrently
with the submission of this letter, the Company is submitting the Amendment No.2 to the Registration Statement (the “Amendment
No. 2”) on Form F-1 together with certain exhibits via EDGAR with the Commission.

For the convenience of the Staff, each
of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment 1 to Form F-1 filed July 26, 2023

Representative’s Warrant, page 100

1. We note that the total number of ADs purchasable with the Representative’s Warrant for both the over
allotment option and the non-over allotment option are blank. Please revise to provide the total number of ADs.

RESPONSE: In
response to the Staff’s comments, we have revised and included the total number of ADs purchasable with the Representative’s
Warrant for both the over allotment option and the non-over allotment option.

2. We note that the Form of the Representative’s Warrant includes a provision that any legal action may
only be instituted in a state or federal court in the city of Los Angeles, California. Please add a discussion in risk factors that clearly
describes any risks or other impacts on potential investors. Risks may include, but are not limited to, increased costs to bring a claim
and that these provisions can discourage claims or limit investors’ ability to bring a claim in a judicial forum that they find
favorable. The disclosure should address any uncertainty about enforceability.

RESPONSE: In
response to the Staff’s comments, we respectfully advise the Staff that we have included such a risk factor on page 26 under the
heading “The form of Representative’s Warrant provides that any legal action may only be instituted in a state or federal
court in the city of New York, New York, which may result in holders of the Representative’s Warrant having limited choice of forum
and limited ability to obtain a favorable judicial forum for complaints against us or our respective directors, officers or employees.”
We have made conforming revisions throughout the document accordingly.

Exhibit Index

Exhibit 5.2 - Opinion of Bevilacqua PLLC regarding the Underwriter’s
Warrant, page II-1

3. We note that your legal opinion states that “Because the Representative’s Warrant contains
provisions stating that they are to be governed by the laws of the State of New York, we are rendering this opinion as to New York law.”
However, the Form of the Representative’s Warrant (Exhibit 4.3) states that the governing law is the State of California. Please revise
and reconcile as to the governing law of the Representative’s Warrant.

RESPONSE:
In response to the Staff’s comments, we have revised the Form of the Representative’s Warrant to reflect that any legal action
may only be instituted in a state or federal court in the city of New York, New York.

If you would like to discuss any of the responses to the Staff’s
comments or if you would like to discuss any other matters, please contact the undersigned at +34 961 196 250 or Louis Bevilacqua of Bevilacqua
PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    TURBO ENERGY, S.A.

    By:
    /s/ Enrique Selva Bellvis

    Name:
     Enrique Selva Bellvis

    Title:
    Chief Executive Officer

cc: Louis A. Bevilacqua, Esq., Bevilacqua PLLC

United States securities and exchange commission logo
August 4, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Amendment No. 1 to Registration Statement on Form F-1
Filed July 26, 2023
File No. 333-273198
Dear Emilio Cañavate:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 17, 2023 letter.
Amendment 1 to Form F-1 filed July 26, 2023
Representative's Warrant, page 100
1.We note that the total number of ADs purchasable with the Representative's Warrant for
both the over allotment option and the non-over allotment option are blank. Please revise
to provide the total number of ADs.
2.We note that the Form of the Representative's Warrant includes a provision that any legal
action may only be instituted in a state or federal court in the city of Los Angeles,
California. Please add a discussion in risk factors that clearly describes any risks or other
impacts on potential investors. Risks may include, but are not limited to, increased costs to

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 August 4, 2023 Page 2
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
August 4, 2023
Page 2
bring a claim and that these provisions can discourage claims or limit investors’ ability to
bring a claim in a judicial forum that they find favorable. The disclosure should address
any uncertainty about enforceability.
Exhibit Index
Exhibit 5.2 - Opinion of Bevilacqua PLLC regarding the Underwriter's Warrant, page II-1
3.We note that your legal opinion states that "Because the Representative’s Warrant
contains provisions stating that they are to be governed by the laws of the State of New
York, we are rendering this opinion as to New York law." However, the Form of the
Representative's Warrant (Exhibit 4.3) states that the governing law is the State of
California. Please revise and reconcile as to the governing law of  the
Representative's Warrant.
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.

Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        Louis A. Bevilacqua

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Turbo Energy, S.A.

Street Isabel la Católica, 8, Door 51,

Valencia, Spain 46004

July 26th, 2023

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

  Attn:
  Eiko Yaoita Pyles

  Anne McConnell

  Sarah Sidwell

  Erin Purnell

  Re:
  Turbo Energy, S.A.

  Registration Statement on Form F-1

  Filed July 11, 2023

  File No. 333-273198

Ladies and Gentlemen:

We hereby submit the responses of Turbo
Energy, S.A. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated July 17, 2023, providing the Staff’s
comments with respect to the Company’s Registration Statement on Form F-1 Filed on July 11, 2023. Concurrently with the submission
of this letter, the Company is submitting the Amendment No.1 to the Registration Statement (the “Amendment No. 1”)
on Form F-1 together with certain exhibits via EDGAR with the Commission.

For the convenience of the Staff, each
of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Registration Statement on Form F-1

Capitalization, page 36

1. We note from your disclosure on page 68 that the amount due to related parties
is €3.8 million as of June 30, 2023 which is significantly higher than the amount due to related parties as of December 31, 2022.
Please provide a footnote to the Capitalization table to quantify the amount due to related parties as of June 30, 2023 and explain how
the amount arose. Please also disclose when and how you expect to repay the amount due to related parties and specially address if any
offering proceeds will be used to repay related parties.

RESPONSE:
In response to the Staff’s comments, we have revised and included a footnote in the Capitalization table to detail the amount
owed to the parent company, Umbrella Solar Investment, and have provided details as to how and when it intends to repay such debt. We
have also clarified that none of the proceeds of this offering will be used to repay related parties.

Description of Share Capital, page 72

2. We note your disclosure on page 72 regarding a future share capital authorization
by Umbrella Solar Investment, S.A. You disclose a maximum amount of “eleven million two hundred and fifty thousand euros,” however
you include (€20,250,000) as well. Please revise to reconcile.

RESPONSE:
In response to the Staff’s comments, we have revised the language to resolve the discrepancy on page 72. The correct number
of maximum amount should be twenty million seven thousand euros (20,700,000€).

Governing Law/Waiver of Jury Trial, page 89

3. We note that the deposit agreement includes a provision that any legal action may only be instituted
in a state or federal court in the city of New York. Please add a discussion in risk factors that clearly describes any risks or other
impacts on investors. Risks may include, but are not limited to, increased costs to bring a claim and that these provisions can discourage
claims or limit investors’ ability to bring a claim in a judicial forum that they find favorable. The disclosure should address
any uncertainty about enforceability.

RESPONSE:
In response to the Staff’s comments, we respectfully advise the Staff that we had included such a risk factor on page 26 under the
heading “The deposit agreement provides that any legal action may only be instituted in a state or federal court in the city of
New York, which may result in holders of our ADSs or ordinary shares having limited choice of forum and limited ability to obtain a favorable
judicial forum for complaints against us or our respective directors, officers or employees.” We have made conforming revisions
throughout the document accordingly.

4. In addition, we note that the deposit agreement includes a jury trial waiver provision
that applies to claims under the federal securities laws. Please revise to provide clear disclosure in risk factors. Disclosure regarding
the jury trial waiver may include, but is not limited to, increased costs to bring a claim, limited access to information and other imbalances
of resources between the company and shareholders, and that these provisions can discourage claims or limit shareholders’ ability
to bring a claim in a judicial forum that they find favorable. You should address any question regarding whether or not a court would
enforce the provision and the impact on claims arising under other applicable state or federal laws.

RESPONSE:
In response to the Staff’s comments, we respectfully advise the Staff that we had included such a risk factor on page 26 under the
heading “The deposit agreement waives holders of our ADSs’ right to jury trial in any legal proceeding arising out of the
deposit agreement or the ADRs against us and/or the depository, which could result in less favorable outcomes to the plaintiffs in any
of such actions.” We have made conforming revisions throughout the document accordingly.

    2

Consolidated Financial Statements

Note 21 - Restatement of Financial
Statements, page F-25

5. In your response to our prior comment 2, we note you revised the Weighted Average
Number of Common Shares Outstanding used in your fiscal 2022 EPS calculation from 1,126,796 shares, as previously presented in your Draft
Registration Statement filed on May 25, 2023, to 359,673 shares. However, if you retroactively reflect both the December stock issuance
and the 20-for-1 forward stock split in your historical EPS calculations, as suggested in prior comment 2, the Weighted Average Number
of Common Shares Outstanding used in both your fiscal 2022 and 2021 EPS calculations would be significantly higher than the shares you
used in your initial calculations and your revised calculation such that the number of shares outstanding in both fiscal periods would
exceed 50,000,000 shares. We note both the December share issuance and the 20-for-1 forward stock split had no impact on the ownership
of the Company but significantly impacted the number of shares outstanding and capital structure of the Company going forward. We also
note, on a post stock split basis, the per share price of the December share issuance was nominal relative to the anticipated IPO price.
As previously requested, please revise your calculations of basic and diluted earnings per share for all periods presented (fiscal 2021
and 2022) to retro-actively reflect both the December stock issuance and the 20-for-1 forward stock split or explain to us why you do
not believe such revisions are required based on consideration of the guidance in paragraphs 21, 26, 28, and 64 of IAS 33.

RESPONSE: In response to the Staff’s
comments, we have revised and updated calculations of basic and diluted earnings per share for all periods presented (fiscal 2021 and
2022) to retro-actively reflect both the 2022 December stock issuance and the 20-for-1 forward stock split.

    3

If you would like to discuss any of the responses to the Staff’s
comments or if you would like to discuss any other matters, please contact the undersigned at +34 961 196 250 or Louis Bevilacqua of Bevilacqua
PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    TURBO ENERGY, S.A.

    By:
    /s/ Enrique Selva Bellvis

    Name:
    Enrique Selva Bellvis

    Title:
    Chief Executive Officer

    cc:
    Louis A. Bevilacqua, Esq., Bevilacqua PLLC

4

United States securities and exchange commission logo
July 17, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Registration Statement on Form F-1
Filed July 11, 2023
File No. 333-273198
Dear Emilio Cañavate:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Capitalization, page 36
1.We note from your disclosure on page 68 that the amount due to related parties is €3.8
million as of June 30, 2023 which is significantly higher than the amount due to related
parties as of December 31, 2022.  Please provide a footnote to the Capitalization table to
quantify the amount due to related parties as of June 30, 2023 and explain how the amount
arose.  Please also disclose when and how you expect to repay the amount due to related
parities and specially address if any offering proceeds will be used to repay related parties.
Description of Share Capital, page 72
2.We note your disclosure on page 72 regarding a future share capital authorization by

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 July 17, 2023 Page 2
 FirstName LastNameEmilio Cañavate
Turbo Energy, S.A.
July 17, 2023
Page 2
Umbrella Solar Investment, S.A. You disclose a maximum amount of "eleven million two
hundred and fifty thousand euros," however you include (€20,250,000) as well. Please
revise to reconcile.
Governing Law/Waiver of Jury Trial, page 89
3.We note that the deposit agreement includes a provision that any legal action may only be
instituted in a state or federal court in the city of New York. Please add a discussion in
risk factors that clearly describes any risks or other impacts on investors. Risks may
include, but are not limited to, increased costs to bring a claim and that these provisions
can discourage claims or limit investors’ ability to bring a claim in a judicial forum that
they find favorable. The disclosure should address any uncertainty about enforceability.
4.In addition, we note that the deposit agreement includes a jury trial waiver provision that
applies to claims under the federal securities laws. Please revise to provide clear
disclosure in risk factors. Disclosure regarding the jury trial waiver may include, but is not
limited to, increased costs to bring a claim, limited access to information and other
imbalances of resources between the company and shareholders, and that these provisions
can discourage claims or limit shareholders’ ability to bring a claim in a judicial forum
that they find favorable. You should address any question regarding whether or not a court
would enforce the provision and the impact on claims arising under other applicable state
or federal laws.
Consolidated Financial Statements
Note 21 - Restatement of Financial Statements, page F-25
5.In your response to our prior comment 2, we note you revised the Weighted Average
Number of Common Shares Outstanding used in your fiscal 2022 EPS calculation from
1,126,796 shares, as previously presented in your Draft Registration Statement filed on
May 25, 2023, to 359,673 shares.  However, if you retroactively reflect both the
December stock issuance and the 20-for-1 forward stock split in your historical EPS
calculations, as suggested in prior comment 2, the Weighted Average Number of
Common Shares Outstanding used in both your fiscal 2022 and 2021 EPS calculations
would be significantly higher than the shares you used in your initial calculations and your
revised calculation such that the number of shares outstanding in both fiscal periods would
exceed 50,000,000 shares.  We note both the December share issuance and the 20-for-1
forward stock split had no impact on the ownership of the Company but significantly
impacted the number of shares outstanding and capital structure of the Company going
forward.  We also note, on a post stock split basis, the per share price of the December
share issuance was nominal relative to the anticipated IPO price.  As previously requested,
please revise your calculations of basic and diluted earnings per share for all periods
presented (fiscal 2021 and 2022) to retro-actively reflect both the December stock
issuance and the 20-for-1 forward stock split or explain to us why you do not believe such
revisions are required based on consideration of the guidance in paragraphs 21, 26, 28,

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 July 17, 2023 Page 3
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
July 17, 2023
Page 3
and 64 of IAS 33.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        Louis A. Bevilacqua

CORRESP
1
filename1.htm

Turbo Energy, S.A.

Street Isabel la Católica, 8, Door 51,

Valencia, Spain 46004

July 11, 2023

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Eiko Yaoita Pyles

Anne McConnell

Sarah Sidwell

Erin Purnell

 Re: Turbo Energy, S.A.

Amendment No. 2 to Draft Registration
Statement on Form F-1

Submitted May 25, 2023

CIK No. 0001963439

Ladies and Gentlemen:

We hereby submit the responses of Turbo Energy,
S.A. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) set forth in the Staff’s letter, dated June 2, 2023, providing the Staff’s
comments with respect to the Company’s Amendment No. 2 to Draft Registration Statement on Form F-1 confidentially submitted on May
25, 2023. Concurrently with the submission of this letter, the Company is submitting the Registration Statement (the “Registration
Statement”) on Form F-1 together with certain exhibits via EDGAR with the Commission.

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Draft Registration Statement on Form F-1 submitted May 25, 2023

Related Party Transactions, page 67

    1.
    Item 7.B. of Form 20-F requires that you include information since the beginning of the company’s preceding three financial years up to the date of the document. Please revise.

RESPONSE: In response to the
Staff’s comments, we have revised the related party transactions disclosure on page 68 to include information since the beginning
of the company’s preceding three financial years up to the date of the document.

Consolidated Financial Statements

Note 12 - Share Capital, page F-20

    2.
    We note in February 2023 the Company approved a forward stock split on a 20-for-1 basis that increased your issued and outstanding share capital from 2,504,285 ordinary shares to 50,085,700 ordinary shares. We also note during December 2022 you issued 50,000,000 shares (2,500,000 shares on a pre-stock split basis) of common stock for proceeds of €2,500,000, to your parent company, who is also your sole shareholder. Given the impact of the share issuance during December 2022 and the forward stock split in February 2023 relative to the Company’s historical capitalization, neither of which impacted the ownership of the Company, please explain to us how and why you determined it would not be more appropriate to also retro-actively reflect the share issuance that occurred during December 2022 in determining the number of shares outstanding used to calculate earnings per share during each period presented, similar to the treatment of the forward stock split. Please specifically address your consideration of paragraphs 21, 26, 28, and 64 of IAS 33. In this regard, it appears the December share issuance may lack substance and the current earnings per share disclosures are not indicative of the actual capitalization of the Company going forward.

RESPONSE: In response to the
Staff’s comments, we have included a restatement of the financial statements to disclose an adjustment on weighted average of issued
and outstanding ordinary shares due to forward stock split of issued and outstanding ordinary shares on a 20-for-1 basis effective in
February 2023.

If you would like to discuss any of
the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +34 961
196 250 or Louis Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    TURBO ENERGY, S.A.

    By:
    /s/ Enrique Selva Bellvis

    Name:
    Enrique Selva Bellvis

    Title:
    Chief Executive Officer

    cc:
    Louis A. Bevilacqua, Esq., Bevilacqua PLLC

United States securities and exchange commission logo
June 2, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted May 25, 2023
CIK No. 0001963439
Dear Emilio Cañavate:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted May 25, 2023
Related Party Transactions, page 67
1.Item 7.B. of Form 20-F requires that you include information since the beginning of the
company’s preceding three financial years up to the date of the document. Please revise.
Consolidated Financial Statements
Note 12 - Share Capital, page F-20
2.We note in February 2023 the Company approved a forward stock split on a 20-for-1 basis
that increased your issued and outstanding share capital from 2,504,285 ordinary shares to
50,085,700 ordinary shares. We also note during December 2022 you issued 50,000,000

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 June 2, 2023 Page 2
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
June 2, 2023
Page 2
shares (2,500,000 shares on a pre-stock split basis) of common stock for proceeds of
€2,500,000, to your parent company, who is also your sole shareholder. Given the
impact of the share issuance during December 2022 and the forward stock split in
February 2023 relative to the Company’s historical capitalization, neither of which
impacted the ownership of the Company, please explain to us how and why you
determined it would not be more appropriate to also retro-actively reflect the share
issuance that occurred during December 2022 in determining the number of shares
outstanding used to calculate earnings per share during each period presented, similar to
the treatment of the forward stock split. Please specifically address your consideration of
paragraphs 21, 26, 28, and 64 of IAS 33. In this regard, it appears the December share
issuance may lack substance and the current earnings per share disclosures are not
indicative of the actual capitalization of the Company going forward.
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        Louis A. Bevilacqua

United States securities and exchange commission logo
April 14, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 31, 2023
CIK No. 0001963439
Dear Emilio Cañavate:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Confidential Draft Registration Statement on Form F-1
Cover Page
1.We note your revisions in response to comment 2. Given Enrique Selva Bellvis'
ownership of Umbrella Solar Investment and Crocodile Investment, please revise to
identify Mr. Bellvis as a controlling shareholder here and in your disclosure on page 27.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 April 14, 2023 Page 2
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
April 14, 2023
Page 2
Risk Factors
We are dependent on a limited number of suppliers for our batteries, inverters, and photovoltaic
modules and the inability of these supplier, page 20
2.We note in your disclosure that you experienced a supply constraint with Chinese
suppliers in 2022. Please expand you disclosure regarding this constraint and the effects
such constraint had on the Company's business.
Principal Shareholders, page 66
3.We note your response to comment 13 and reissue in part. We note you have excluded
shares from the beneficial ownership of Mr. Bellvis. Please revise each
individual's beneficial ownership to include all shares each individual beneficially owns,
whether or not also beneficially owned by another person or entity in the table, which can
be explained in the footnotes. In the alternative, please explain how you determined that
Mr. Bellvis does not have beneficial ownership of the shares held by Umbrella
Investment.
Related Party Transactions, page 67
4.Please revise your disclosure to comply with Item 4(a) of Form F-1 and Item 7(B) of
Form 20-F.
Financial Statements
Note 10 - Related Party Transactions, page F-16
5.We note your response to prior comment 15; however, based on the disclosed amounts of
related party transactions that occurred during the period, please more fully explain why
the cash flows for related party advances and repayments significantly exceed the related
party transaction amounts. In addition, based on your response and the nature of the
related party transactions, please also more fully explain how you determined the related
party cash flows are appropriately classified as financing activities under IAS 7.
6.We note your response to prior comment 16. In regard to the first bullet, please disclose
the information you provided in your response in note 10 and also disclose the number of
entities the parent company allocates expenses to. We also note your response to the
second and third bullets indicates the historical financial statements appropriately reflect
all costs of doing business and no additional costs would be required to be reflected in
historical or pro forma financial statements. Please also disclose this information in note
10.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 April 14, 2023 Page 3
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
April 14, 2023
Page 3
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        Louis A. Bevilacqua

United States securities and exchange commission logo
March 24, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Draft Registration Statement on Form F-1
Submitted February 28, 2023
CIK No. 0001963439
Dear Emilio Cañavate:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted February 28, 2023
Cover Page
1.We note your disclosure on page 95 that you are registering the Representative's Warrant
and the ADSs issuable upon exercise of such warrant. Please revise to prominently
disclose the warrant and underlying shares on the cover page. In addition, you refer to
both the representative's "warrants" and "warrant" in various places throughout the
prospectus. Please revise to clearly state whether you are offering one warrant or multiple
warrants and please state the appropriate conversion terms.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 March 24, 2023 Page 2
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
March 24, 2023
Page 2
2.We note that you expect to be a "controlled company" under the rules of the Nasdaq Stock
Market. Please revise to identify the controlling shareholder and its ownership percentage.
In addition, please revise the cross reference to specifically refer to the relevant risk factor
on page 26. Please revise the discussion in risk factors to address the potential risks
associated with being a controlled company under Nasdaq rules.
Prospectus Summary
The Company, page 6
3.Please revise your summary to include a specific, clear overview of your current
operations, product markets, and distribution methods, with a fuller description appearing
in your business section.  Refer to Item 101(h)(4) of Regulation S-K.  Distinguish clearly
your aspirations from your accomplishments.
4.We note that you offer a "Turbo Energy App" to provide services related to the solar
energy products. Please expand your disclosure to describe the company's role in the
development and association with this application.
5.Please provide further disclosure with regard to the names of your principal suppliers,
including the primary battery supplier located in China and primary SunBox supplier in
Spain. See Item 101(h)(4)(v) of Regulation S-K.
Summary Consolidated Financial Information, page 14
6.It appears that you intend to present dollar equivalent or convenience translations as of
and for each of the years ended December 31, 2022 and 2021 here and in MD&A.
Please be advised convenience translations may only be presented for the most recent
fiscal year and any subsequent interim period using the exchange rate as of the most
recent balance sheet date included in the filing or, the most recent date practicable, if
materially different. Please ensure your presentation complies with Rule 3-20(b)(1) of
Regulation S-X.
Risk Factors
Economic conditions may adversely affect consumer spending and the overall general health of
our retail customers..., page 19
7.We note your risk factor disclosure indicating that inflation could affect consumer
purchases of discretionary items. We also note your disclosure on page 42 that you do not
expect inflation to have a material impact on the company. Since you have included in
your disclosure that Spanish inflation has increased 6.0% since 2020, please revise to
discuss if recent inflationary pressures have materially impacted your operations. In this
regard, identify the types of inflationary pressures you are facing and how your business
has been affected. Please include a similar discussion in Management's Discussion and
Analysis if applicable.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 March 24, 2023 Page 3
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
March 24, 2023
Page 3
We are dependent on a limited number of suppliers for our batteries..., page 19
8.We note that you rely on suppliers solely located in China. Please disclose the risks of this
reliance and any disruptions you have experienced due to such reliance.
Any compromise of the cybersecurity of our platform..., page 23
9.We note your risk factor regarding cybersecurity risks in connection with the Turbo
Energy App. Please describe the extent and nature of the role of the board of directors in
overseeing cybersecurity risks, including in connection with the company’s supply
chain/suppliers/service providers.
Customers, page 55
10.We note that Sonepar Iberica Spain accounts for more than 10% of total revenue. Please
provide the approximate percentage of total revenue provided by this customer.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Seasonality, page 55
11.Your disclosure that your business is not generally affected by seasonal
fluctuation appears to be inconsistent with the disclosure on page 22 where you state that
your revenue, cash flow, and results of operations may fluctuate due to the seasonal nature
of weather and events. Please revise your disclosure to correct this discrepancy.
Manufacturing and Supply, page 55
12.We note disclosure on page 55 that you use manufacturers for your inverters, batteries and
photovoltaic modules.  Please expand your disclosure to describe the material terms of
your manufacturing arrangements with respect to all your products, including SunBox and
battery products.  File material manufacturing agreements as exhibits to your registration
statement.  Clarify the location(s) where your products are produced, and describe how
you ensure quality control.
Principal Shareholders, page 64
13.We note that you refer to your CEO as Enrique Selva in some places and Enrique Selva
Bellvis in others. Please revise to be consistent. In addition, please revise the disclosure in
footnote 4 to clarify, if true, that Crocodile Investment S.L.U. and Enrique Selva Bellvis
own the majority of the shares of Umbrella Solar Investment. Please quantify their
percentages of ownership and explain how you determined that Mr. Bellvis does not have
beneficial ownership of the shares held by Umbrella Solar Investment.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 March 24, 2023 Page 4
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
March 24, 2023
Page 4
Financial Statements
Note 5 - Inventories, page F-15
14.We note the disclosure that the Company outsourced the management of inventories to a
third party with all the inventories located in a warehouse owned by the third parties and
that inventories are not covered by the Company insurance policy. Please more fully
explain the terms of the outsource agreement and the reason why inventories are not
covered by the Company insurance policy.  Please specifically address how the Company
determined it has ownership of the inventory.
Note 10 - Related Party Transactions, page F-16
15.We note that during the year ended December 31, 2021, the Company made advances to
related parties of €3,840,594 and received repayments from related parties of
€3,980,572. Please disclose and discuss the reasons for and nature of the related party
advances.
16.We note that the Company is part of the Umbrella Solar Investment Group, whose main
shareholder is Crocodile Investment. We also note that services received from the
majority shareholder during the year ended December 31, 2021 include supporting
services from the parent company provided centrally for the entire group whose costs
were distributed based on objective and market criteria and that the Company incurred
management fees of €226,222. Please more fully address the following:
•Clarify and disclose the specific objective and market criteria on which parent
company expenses were distributed;
•Clarify and explain the disclosure that no compensation has been paid to the
executives under Crocodile Investment SLU.  In the event the historical financial
statements do not reflect all of the Company’s costs of doing business, explain how
you determined such additional costs are not required to be reflected in the historical
financial financial statements; and
•Explain how you considered the pro forma financial requirements of Rule 11-01(a)(7)
of Regulation S-X.
Note 15 - Financial Instruments and Risk Management
Interest risk, page F-21
17.Your disclosure states that the Company is exposed to interest rate risk on its convertible
debentures; however, we note no disclosures that indicate the Company has
convertible debentures. Please clarify or revise this inconsistency.
18.Please revise your disclosures here, and under Interest Rate Risk on page 42, to include a
discussion of the potential interest rate risks associated with the lines of credit that bear
interest at variable rates.

 FirstName LastNameEmilio Cañavate
 Comapany NameTurbo Energy, S.A.
 March 24, 2023 Page 5
 FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
March 24, 2023
Page 5
General
19.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.  Please contact the staff member associated with the
review of this filing to discuss how to submit such copies.
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing