SecProbe.io

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 June
9, 2025

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F. Street, NE

 Washington,
D.C. 20549

 Attn:
Irene Barberena-Meissner

 Re:
 Vantage
 Corp

 Registration
 Statement on Form F-1, as amended (File No. 333-282566)

 Request
 For Acceleration of Effectiveness

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the "Securities Act"), Network 1 Financial Securities, Inc., acting as representative of the underwriters, hereby
join Vantage Corp in requesting acceleration of the effective date of the above-referenced Registration Statement so that it will become
effective at 4:30 p.m., Eastern Time, on June 11, 2025, or as soon thereafter as practicable.

 Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the preliminary prospectus dated
April 17, 2025, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

 The
undersigned confirm that it has complied and will continue to comply with, and it has been informed or will be informed by participating
dealers that it has complied 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,

 Network
 1 Financial Securities, Inc.

 By:
 /s/
 Adam Pasholk

 Name:
 Adam
 Pasholk

 Title:
 Managing
 Director

CORRESP
 1
 filename1.htm

 VANTAGE
CORP

 VIA
EDGAR

 June
9, 2025

 U.S.
Securities & Exchange Commission

 Division
of Corporation Finance

 Office
of Energy & Transportation

 Washington,
D.C. 20549

 Attn:
Irene Barberena-Meissner and Daniel Morris

 Re:
 Vantage
 Corp (Singapore)

 Registration
 Statement on Form F-1

 Initially
 Filed October 9, 2024, as amended

 File
 No. 333-282566

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Vantage Corp hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4:30 pm, Eastern Time, on June 11, 2025, or as soon as thereafter practicable.

 Very
 truly yours,

 /s/
 Andresian D'Rozario

 Andresian
 D'Rozario

 Chief
 Executive Officer and Director

 cc:
 Loeb
 & Loeb LLP

 Hunter
 Taubman Fischer & Li LLC

CORRESP
 1
 filename1.htm

 March
19, 2025

 Via
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Energy & Transportation

 Washington,
D.C. 20549

 Re:
 Vantage
 Corp (the "Company")

 Amendment
 No. 5 to Registration Statement on Form F-1

 Filed
 February 28, 2025

 File
 No. 333-282566

 Dear
SEC Officers:

 We
hereby provide a response to the comments issued in a letter dated March 11, 2025 (the "Staff's Letter") regarding
the Company's Amendment No. 5 to Registration Statement on Form F-1 (the "Registration Statement"). Contemporaneously,
we are publicly filing the Amendment No. 6 to Registration Statement via Edgar (the "Amended F-1").

 In
order to facilitate the review by the Commission's staff (the "Staff") of the Amended F-1, we have responded to the
comments set forth in the Staff's Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff's
comments and correspond to the numbered paragraph in the Staff's Letter.

 Amendment
No. 5 to Registration Statement on Form F-1

 Exhibits

 1.
 We
 note the executed director nominee consents you previously filed as Exhibits 99.4, 99.5, and 99.6 are undated. Please file
 dated versions of these consents as exhibits.

 Response:
 The executed and dated director nominee consents are being filed as Exhibits 99.4, 99.5, and 99.6 to the Amended F-1.

 General

 2.
 Please
 revise your prospectus to disclose the material terms of the Clawback Policy adopted by your Board of Directors and filed with this
 amendment as Exhibit 99.8.

 Response:
 The Company has revised the disclosure on page 71 of the Amended F-1 in response to the Staff's comment to disclose the
 material terms of the Clawback Policy.

 Please
reach Lawrence Venick, the Company's outside counsel at (310) 728-512 if you would like additional information with respect to
any of the foregoing. Thank you.

 Sincerely,

 /s/
 Andresian D'Rozario

 Andresian
 D'Rozario

 Vantage
 Corp

 Chief
 Executive Officer

 Encl.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 11, 2025

Andresian D Rozario
Chief Executive Officer and Chairman of the Board
Vantage Corp (Singapore)
#05-06, Level 5, 51 Cuppage Road
Singapore 229469

 Re: Vantage Corp (Singapore)
 Amendment No. 5 to Registration Statement on Form F-1
 Filed February 28, 2025
 File No. 333-282566
Dear Andresian D Rozario:

 We have reviewed your amended registration statement and have the
following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Amendment No. 5 to Registration Statement on Form F-1
Exhibits

1. We note the executed director nominee consents you previously filed as
Exhibits 99.4,
 99.5, and 99.6 are undated. Please file dated versions of these consents
as exhibits.
General

2. Please revise your prospectus to disclose the material terms of the
Clawback
 Policy adopted by your Board of Directors and filed with this amendment
as Exhibit
 99.8.
 March 11, 2025
Page 2

 Please contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Yong
Kim, Staff
Accountant, at 202-551-3323 if you have questions regarding comments on the
financial
statements and related matters. Please contact Irene Barberena-Meissner, Staff
Attorney, at
202-551-6548 or Daniel Morris, Legal Branch Chief, at 202-551-3314 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Lawrence Venick, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

January 24, 2025

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

Washington, D.C. 20549

    Re:
    Vantage Corp (the “Company”)

    Amendment No. 3 to Registration Statement on Form F-1

    Filed January 10, 2025

    File No. 333-282566

Dear SEC Officers:

We hereby provide a response to
the comments issued in a letter dated January 23, 2025 (the “Staff’s Letter”) regarding the Company’s Amendment
No. 3 to Registration Statement on Form F-1 (the “Registration Statement”). Contemporaneously, we are publicly filing the
Amendment No. 4 to Registration Statement via Edgar (the “Amended F-1”).

In order to facilitate the review
by the Commission’s staff (the “Staff”) of the Amended F-1, we have responded to the comments set forth in the Staff’s
Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s comments and correspond to the
numbered paragraph in the Staff’s Letter.

Amendment No. 3 to Registration Statement on Form
F-1 filed January 10, 2025

Use of Proceeds , page 29

    1.
    We note your disclosure on page 73 that, as of September 30, 2024, Vantage Singapore declared interim dividends totaling US$11,849,995 of which US$357,995 was offset against amounts due from directors. We further note your unaudited condensed combined balance sheet as of September 30, 2024 discloses a dividend payable in the amount of $11,492,000 and cash and cash equivalents in the amount $4,128,573. As it appears that, as of September 30, 2024, you do not sufficient cash to pay this declared dividend, please clarify whether you intend to use net proceeds from this offering to pay this dividend.

    Response:
    The Company respectfully submits and confirms that the proceeds from this offering will not be utilized to pay the declared dividend.
    As of the date of the prospectus, Vantage Singapore has declared interim dividends totaling US$11,849,995, of which US$778,211 was
    offset against amounts due from directors. The remaining dividend payable is US$11,071,784. Vantage Singapore’s current bank
    balance is US$8.8 million, with trade receivables totaling US$3.2 million. We intend to use a combination of our existing bank balance
    and trade receivables to fully satisfy the dividend payment of US$11,071,784. We plan to distribute the dividend within the next six months. To ensure
the dividend is paid from liquid assets, we are actively increasing our bank balance and collecting outstanding receivables. We are committed
to keeping the net proceeds from this offering separate from dividend funds by depositing them into a distinct bank account, ensuring
they are not used for dividend payments.

Concentration of Vendors, page 45

    2.
    We note the allocations of your accounts payable and commissions have change drastically in the past twelve months, in particular the prominence of Vendors E and I, respectively. Please add contextualizing disclosure to explain why you experienced such significant changes in allocation during the most recent fiscal year, whether such changes are typical, and the risks, if any, to your company which may result.

    Response: The Company has revised the disclosure on pages 11 and 45 of the Amended F-1 in response to the Staff’s comment.

Related Party Transactions, page 73

    3.
    We note you have provided a summary of related party transactions since 2021 to September 30, 2024. Please revise these disclosures to include information since the beginning of the company’s preceding three financial years (currently, April 1, 2021) up to the date of your prospectus. Refer to Item 7.B of Form 20-F.

    Response: The Company has revised the disclosure on page 73 of the Amended F-1 in response to the Staff’s comment.

Please reach Lawrence Venick,
the Company’s outside counsel at (310) 728-512 if you would like additional information with respect to any of the foregoing. Thank
you.

Sincerely,

    /s/ Andresian D’Rozario

    Andresian D’Rozario

    Vantage Corp

    Chief Executive Officer

    Encl.

January 23, 2025
Andresian D’Rozario
Chief Executive Officer and Chairman of the Board
Vantage Corp (Singapore)
#05-06, Level 5, 51 Cuppage Road
Singapore 229469
Re:Vantage Corp (Singapore)
Amendment No. 3 to Registration Statement on Form F-1
Filed January 10, 2025
File No. 333-282566
Dear Andresian D’Rozario:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No. 3 to Registration Statement on Form F-1 filed January 10, 2025
Use of Proceeds , page 29
1.We note your disclosure on page 73 that, as of September 30, 2024, Vantage
Singapore declared interim dividends totaling US$11,849,995 of which US$357,995
was offset against amounts due from directors. We further note your unaudited
condensed combined balance sheet as of September 30, 2024 discloses a dividend
payable in the amount of $11,492,000 and cash and cash equivalents in the amount
$4,128,573. As it appears that, as of September 30, 2024, you do not sufficient cash to
pay this declared dividend, please clarify whether you intend to use net proceeds from
this offering to pay this dividend.
Concentration of Vendors, page 45
We note the allocations of your accounts payable and commissions have changed 2.

January 23, 2025
Page 2
drastically in the past twelve months, in particular the prominence of Vendors E and I,
respectively. Please add contextualizing disclosure to explain why you experienced
such significant changes in allocation during the most recent fiscal year, whether
such changes are typical, and the risks, if any, to your company which may result.
Related Party Transactions, page 73
3.We note you have provided a summary of related party transactions since 2021 to
September 30, 2024. Please revise these disclosures to include information since the
beginning of the company’s preceding three financial years (currently, April 1, 2021)
up to the date of your prospectus. Refer to Item 7.B of Form 20-F.
            Please contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Yong Kim, Staff
Accountant, at 202-551-3323 if you have questions regarding comments on the financial
statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 or Daniel Morris, Legal Branch Chief, at 202-551-3314 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Lawrence Venick, Esq.

CORRESP
1
filename1.htm

December
19, 2024

Via
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

Washington,
D.C. 20549

    Re:
    Vantage
    Corp (the “Company”)

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

    Filed
    November 20, 2024

    File
    No. 333-282566

Dear
SEC Officers:

We
hereby provide a response to the comments issued in a letter dated December 17, 2024 (the “Staff’s Letter”) regarding
the Company’s Amendment No. 1 to Registration Statement on Form F-1 (the “Registration Statement”). Contemporaneously,
we are publicly filing the Amendment No. 2 to Registration Statement via Edgar (the “Amended F-1”).

In
order to facilitate the review by the Commission’s staff (the “Staff”) of the Amended F-1, we have responded to the
comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s
comments and correspond to the numbered paragraph in the Staff’s Letter.

Registration
Statement on Form F-1 filed November 20, 2024

Risk
Factors, page 10

    1.
    Please
    resolve the inconsistency between the estimated as adjusted net tangible book value of $0.70 per share cited in the first paragraph
    on page 17, and the corresponding figure of $0.63 per share shown in the dilution table on page 32.

    Response:
    The Company has revised the disclosure on page 17 of the Amended F-1 in response to the Staff’s comment.

Capitalization,
page 31

    2.
    Please
    revise your introductory points to more clearly describe the pro forma, and the pro forma as adjusted scenarios, to include a description
    of the adjustments reflected therein. For example, we understand that your pro forma scenario would reflect adjustments associated
    with the reorganization, and that your pro forma as adjusted scenario would also reflect adjustments associated with the offering.

    Please
    also modify the “Adjusted Pro Forma “ column label to read “Pro Forma As Adjusted” so that this will align
    with your references to this scenario, and revise your line item notations as necessary to reflect information for each of the actual,
    pro forma, and pro forma as adjusted scenarios.

    For
    example, it appears that your description of ordinary shares should indicate there was just one share outstanding on an actual basis
    (based on your audited financial statements), 28,000,000 shares outstanding on a pro forma basis (reflecting the reorganization),
    and 31,250,000 shares outstanding on a pro forma as adjusted basis (reflecting both the reorganization and the initial public offering).

    Response:
    The Company has revised the disclosure on page 31 of the Amended F-1 in response to the Staff’s comment.

Management

Executive
Officers and Directors, page 64

    3.
    Please
    revise the biographical information provided for your director nominee, Jensen Per Juul, to describe his business experience during
    the past five years. Refer to Item 401(e) of Regulation S-K.

    Response:
    The Company has revised the disclosure on page 64 of the Amended F-1 in response to the Staff’s comment.

Financial
Statements, page F-1

    4.
    We
    note that you have appropriately identified the financial statements and related notes on pages F-3 through F-26 as combined financial
    statements, and notes to combined financial statements, and on page F-8 you have identified the two entities for which the accounts
    have been combined in this presentation as Vantage Shipbrokers Pte. Ltd. (Singapore) and Vantage Nexus Commercial Brokers Co. L.L.C.
    (Dubai).

    As
    such, the labeling that you have included on pages F-3 through F-7, identifying the financial statements as “Vantage Corp and
    its Subsidiaries” is not consistent as it refers to the entity to which the operations are intended to be contributed, and
    it implies a parent-subsidiary relationship and consolidated financial presentation.

    Therefore,
    it appears that you should replace the labels “Vantage Corp and its Subsidiaries” on pages F-3 through F-7, and any corresponding
    references to these financial statements elsewhere in the filing, with “Vantage Shipbrokers Pte. Ltd. (Singapore) and Vantage
    Nexus Commercial Brokers Co L.L.C. (Dubai).” Please also ask your auditors to similarly revise the references to these financial
    statements in the audit opinion on page F-2, and in the auditor consent at Exhibit 23.1.

    Response:
    The Company has revised the disclosures throughout the F-pages of the Amended F-1 in response to the Staff’s comment. The
    references to the financial statements in the audit opinion on page F-2, and in the auditor consent at Exhibit 23.1 were also revised
    accordingly.

General

    5.
    We
    understand from your disclosure on page II-1 that you may have completed the reorganization on October 15, 2024, with the issuance
    of 7,633,620 Class A Ordinary Shares and 20,366,379 Class B Ordinary Shares to the shareholders of Vantage BVI (including Ho Ying
    Keat Lowell, Andresian D’Rozario, Francis Junior James, Randy Yong Choon Hong, and Quah Choong Hua, and other shareholders).

    Unless
    there are other aspects of the reorganization that are yet to occur, it appears that you woud need to revise disclosures throughout
    your filing to clearly convey that the reorganization occurred on October 15, 2024, or to otherwise provide an update regarding the
    status of the reorganization.

    As
    part of your revisions, please update the reorganization disclosure on page F-7 and your capitalization disclosure on page 31. In
    addition, please clarify how the Class A and Class B Ordinary Shares were apportioned among the minority shareholders and the five
    principal shareholders listed above.

    Response:
    The Company has revised the disclosures on the cover page and pages 5, 31, 44, F-7 and F-8 of the Amended F-1 in response to
    the Staff’s comment to clarify that the Reorganization has been completed in November 2024.

    The
    Company respectfully advises the Staff that the Ordinary Shares were allocated pro rata based on each shareholder’s previous
    holdings in Vantage BVI, such that post-Reorganization (but pre-IPO), the percentage ownership of each shareholder in the Company
    is the same as their previous holding in Vantage BVI. Holders of Class A Ordinary Shares are entitled to one vote per share, while
    holders of Class B Ordinary Shares are entitled to ten votes per share. Given that the five principal shareholders, who are also
    the founders and senior management of the Group, have been managing the Group since its inception, the Company believes it is in
    its best interest to grant them greater voting power. Therefore, the five principal shareholders received Class B Ordinary Shares,
    while the minority shareholders, being passive investors, received Class A Ordinary Shares.  The Company has revised the disclosures
    on the page II-1 of the Amended F-1 to clarify accordingly.

Please
reach Lawrence Venick, the Company’s outside counsel at (310) 728-512 if you would like additional information with respect to
any of the foregoing. Thank you.

Sincerely,

    /s/
    Andresian D’Rozario

    Andresian
    D’Rozario

    Vantage
    Corp

    Chief
    Executive Officer

    Encl.

December 17, 2024
Andresian D’Rozario
Chief Executive Officer and Chairman of the Board
Vantage Corp (Singapore)
#05-06, Level 5, 51 Cuppage Road
Singapore 229469
Re:Vantage Corp (Singapore)
Amendment No. 1 to Registration Statement on Form F-1
Filed November 20, 2024
File No. 333-282566
Dear Andresian D’Rozario:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1 filed November 20, 2024
Risk Factors, page 10
1.Please resolve the inconsistency between the estimated as adjusted net tangible book
value of $0.70 per share cited in the first paragraph on page 17, and the corresponding
figure of $0.63 per share shown in the dilution table on page 32.

Capitalization, page 31
Please revise your introductory points to more clearly describe the pro forma, and the
pro forma as adjusted scenarios, to include a description of the adjustments reflected
therin. For example, we understand that your pro forma scenario would reflect
adjustments associated with the reorganization, and that your pro forma as adjusted
scenario would also reflect adjustments associated with the offering.2.

December 17, 2024
Page 2

Please also modify the "Adjusted Pro Forma " column label to read "Pro Forma As
Adjusted" so that this will align with your references to this scenario, and revise your
line item notations as necessary to reflect information for each of the actual, pro
forma, and pro forma as adjusted scenarios.

For example, it appears that your description of ordinary shares should indicate there
was just one share outstanding on an actual basis (based on your audited financial
statements), 28,000,000 shares outstanding on a pro forma basis (reflecting the
reorganization), and 31,250,000 shares outstanding on a pro forma as adjusted basis
(reflecting both the reorganization and the initial public offering).

Management
Executive Officers and Directors, page 64
3.Please revise the biographical information provided for your director nominee, Jensen
Per Juul, to describe his business experience during the past five years. Refer to Item
401(e) of Regulation S-K.

Financial Statements, page F-1
4.We note that you have appropriately identified the financial statements and related
notes on pages F-3 through F-26 as combined financial statements, and notes to
combined financial statements, and on page F-8 you have identified the two enties for
which the accounts have been combined in this presentation as Vantage Shipbrokers
Pte. Ltd. (Singapore) and Vantage Nexus Commercial Brokers Co. L.L.C. (Dubai).

As such, the labeling that you have included on pages F-3 through F-7, identifying the
financial statements as "Vantage Corp and its Subsidiaries" is not consistent as it
refers to the entity to which the operations are intended to be contributed, and it
implies a parent-subsidiary relationship and consolidated financial presentation.

Therefore, it appears that you should replace the labels "Vantage Corp and its
Subsidiaries" on pages F-3 through F-7, and any corresponding references to these
financial statements elsewhere in the filing, with “Vantage Shipbrokers Pte. Ltd.
(Singapore) and Vantage Nexus Commercial Brokers Co L.L.C. (Dubai).” Please also
ask your auditors to similarly revise the references to these financial statements in
the audit opinion on page F-2, and in the auditor consent at Exhibit 23.1.

General
We understand from your disclosure on page II-1 that you may have completed the
reorganization on October 15, 2024, with the issuance of 7,633,620 Class A Ordinary
Shares and 20,366,379 Class B Ordinary Shares to the shareholders of Vantage BVI
(including Ho Ying Keat Lowell, Andresian D’Rozario, Francis Junior James, Randy
Yong Choon Hong, and Quah Choong Hua, and other shareholders). 5.

December 17, 2024
Page 3

Unless there are other aspects of the reorganization that are yet to occur, it appears
that you woud need to revise disclosures throughout your filing to clearly convey that
the reorganization occurred on October 15, 2024, or to otherwise provide an update
regarding the status of the reorganization.

As part of your revisions, please update the reorganization disclosure on page F-7 and
your capitalization disclosure on page 31.  In addition, please clarify how the Class A
and Class B Ordinary Shares were apportioned among the minority shareholders and
the five principal shareholders listed above.

            Please contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Yong Kim, Staff
Accountant, at 202-551-3323 if you have questions regarding comments on the financial
statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 or Daniel Morris, Legal Branch Chief, at 202-551-3314 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Lawrence Venick, Esq.

CORRESP
1
filename1.htm

November
20, 2024

Via
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

Washington,
D.C. 20549

    Re:
    Vantage
    Corp (the “Company”)

    Registration
    Statement on Form F-1

    Filed
    October 9, 2024

    File
    No. 333-282566

Dear
SEC Officers:

We
hereby provide a response to the comments issued in a letter dated November 5, 2024 (the “Staff’s Letter”) regarding
the Company’s Registration Statement on Form F-1 (the “Registration Statement”). Contemporaneously, we are publicly
filing the Amendment No. 1 to Registration Statement via Edgar (the “Amended F-1”).

In
order to facilitate the review by the Commission’s staff (the “Staff”) of the Amended F-1, we have responded to the
comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s
comments and correspond to the numbered paragraph in the Staff’s Letter.

Registration
Statement on Form F-1 filed October 9, 2024

Prospectus
Summary

Our
Corporate Structure and History, page 5

    1.
    The
    organizational structure of Vantage Singapore presented on page 6 shows that five shareholders each owns 14.55% of Vantage Singapore
    and 27.25% is owned by minority shareholders. Reconcile these percentages with the “Acting-in-concert Deed of Confirmation
    by and among the Majority Shareholders” that was entered into on September 20, 2024 and filed on Exhibit 10.2 which states
    that the five shareholders each own 20% of Vantage Singapore.

    Response:
    The Company respectfully advises the Staff that there were shareholding changes among the shareholders of Vantage Singapore subsequent
    to the signing of the Acting-in-concert Deed of Confirmation. The most update shareholdings were accurately disclosed in the Amended
    F-1.

Financial
Statements, page F-1

    2.
    We
    note your response to prior comment 5 and refer you to comment 9 in our July 23, 2024 comment letter. Your next amendment must include
    audited financial statements of the registrant, Vantage Corp., to comply with Item 4 of Form F-1 and Item 8 of Form 20-F. We suggest
    that you contact us by telephone in advance of filing your next amendment if you require further guidance concerning this requirement.

    Response:
    The Company respectfully advises the Staff that audited financial statements of the registrant, Vantage Corp, were included in
    the Amended F-1 starting from page F-27.

Notes
to the Consolidated Financial Statements

1.
Organization and Principal Activities

Reorganization,
page F-7

    3.
    We
    note that in response to prior comment 7 you identify five individuals as a control group for Vantage Singapore, and only one of
    those individuals as having control over Vantage Dubai, notwithstanding the ten percent interests held by two additional members
    of the control group.

    Since
    the same group of individuals do not similarly share control over Vantage Dubai, presenting combined financial statements as if the
    entities had been under common control, would not be appropriate. As such, the combined financial statements currently presented
    should be replaced with separate audited financial statements of Vantage Singapore and Vantage Dubai, covering the most recently
    completed two fiscal years for Vantage Singapore, and the period from the date of formation through the end of the most recently
    completed fiscal year for Vantage Dubai.

    Please
    revise disclosures throughout the filing as necessary to reflect this distinction, including disclosures on page F-7 to clarify that
    there are five individuals that comprise the control group for Vantage Singapore, rather than three shareholders as presently reported.

    Please
    also expand the disclosures within or adjacent to the various organization charts to identify the individuals or entities involved
    in forming Vantage Corp. and Vantage (BVI) Corporation on April 2, 2024, and who will be holding those interests until the reorganization
    occurs.

    Response:
    The Company respectfully advises the Staff that the five individual shareholders have entered into another acting-in-concert
    deed of confirmation dated November 18, 2024, pursuant to which they confirmed and agreed that they have been acting in concert with
    one another in respect of all major affairs concerning Vantage Singapore and Vantage Dubai since they became interested in and possessed
    voting rights in Vantage Singapore and Vantage Dubai, including during the period comprising the two financial years ended March
    31, 2023 and March 31, 2024. Therefore, the Company believes that Vantage Singapore and Vantage Dubai have all along been under common
    control and separate financial statements are not necessary.

    Pages
    6 and 45 of the Amended F-1 have been revised to include organization charts to identify the individuals or entities involved in
    forming Vantage Corp. and Vantage (BVI) Corporation.

General

    4.
    As
    you will need to present separate financial statements for Vantage Singapore and Vantage Dubai, you will also need to present pro
    forma financial statements to illustrate the reorganization and offering proceeds, to the extent of the firm commitment, in accordance
    with Article 11 of Regulation S-X. With regard to the accounting that may apply to the contribution of Vantage Dubai, please refer
    to and address the guidance in SAB Topic 5:G.

    Response:
    The Company respectfully advises the Staff that separate financial statements for Vantage Singapore and Vantage Dubai are not
    necessary, based on the reasons described in the response to comment 3 above.

Please
reach Lawrence Venick, the Company’s outside counsel at +852.5600.0188 if you would like additional information with respect to
any of the foregoing. Thank you.

Sincerely,

    /s/
    Andresian D’Rozario

    Andresian
    D’Rozario

    Vantage
    Corp

    Chief
    Executive Officer

    Encl.

November 5, 2024
Andresian D’Rozario
Chief Executive Officer and Chairman of the Board
Vantage Corp (Singapore)
#05-06, Level 5, 51 Cuppage Road
Singapore 229469
Re:Vantage Corp (Singapore)
Registration Statement on Form F-1
Filed October 9, 2024
File No. 333-282566
Dear Andresian D’Rozario:
            We have reviewed your registration statement and have the following comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.  Unless we note
otherwise, any references to prior comments are to comments in our September 26, 2024
letter.
Registration Statement on Form F-1 filed October 9, 2024
Prospectus Summary
Our Corporate Structure and History, page 5
1.The organizational structure of Vantage Singapore presented on page 6 shows that
five shareholders each owns 14.55% of Vantage Singapore and 27.25% is owned by
minority shareholders.  Reconcile these percentages with the “Acting-in-concert Deed
of Confirmation by and among the Majority Shareholders” that was entered into on
September 20, 2024 and filed on Exhibit 10.2 which states that the five shareholders
each own 20% of Vantage Singapore.
Financial Statements, page F-1
We note your response to prior comment 5 and refer you to comment 9 in our July 23, 2.

November 5, 2024
Page 2
2024 comment letter. Your next amendment must include audited financial statements
of the registrant, Vantage Corp., to comply with Item 4 of Form F-1 and Item 8 of
Form 20-F.  We suggest that you contact us by telephone in advance of filing your
next amendment if you require further guidance concerning this requirement.
Notes to the Consolidated Financial Statements
1. Organization and Principal Activities
Reorganization, page F-7
3.We note that in response to prior comment 7 you identify five individuals as a control
group for Vantage Singapore, and only one of those individuals as having control over
Vantage Dubai, notwithstanding the ten percent interests held by two additional
members of the control group.

Since the same group of individuals do not similarly share control over Vantage
Dubai, presenting combined financial statements as if the entities had been under
common control, would not be appropriate. As such, the combined financial
statements currently presented should be replaced with separate audited financial
statements of Vantage Singapore and Vantage Dubai, covering the most recently
completed two fiscal years for Vantage Singapore, and the period from the date of
formation through the end of the most recently completed fiscal year for Vantage
Dubai.

Please revise disclosures throughout the filing as necessary to reflect this distinction,
including disclosures on page F-7 to clarify that there are five individuals that
comprise the control group for Vantage Singapore, rather than three shareholders as
presently reported.

Please also expand the disclosures within or adjacent to the various organization
charts to identify the individuals or entities involved in forming Vantage Corp. and
Vantage (BVI) Corporation on April 2, 2024, and who will be holding those interests
until the reorganization occurs.
General
4.As you will need to present separate financial statements for Vantage Singapore and
Vantage Dubai, you will also need to present pro forma financial statements to
illustrate the reorganization and offering proceeds, to the extent of the firm
commitment, in accordance with Article 11 of Regulation S-X.  With regard to the
accounting that may apply to the contribution of Vantage Dubai, please refer to and
address the guidance in SAB Topic 5:G.
            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

November 5, 2024
Page 3
statement.
            Please contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Yong Kim, Staff
Accountant, at 202-551-3323 if you have questions regarding comments on the financial
statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 or Daniel Morris, Legal Branch Chief, at 202-551-3314 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Lawrence Venick, Esq.

CORRESP
1
filename1.htm

October
9, 2024

Via
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

Washington,
D.C. 20549

    Re:
    Vantage
    Corp (the “Company”)

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

    Submitted
    August 29, 2024

    CIK
    0002027160

Dear
SEC Officers:

We
hereby provide a response to the comments issued in a letter dated September 26, 2024 (the “Staff’s Letter”) regarding
the Company’s Amendment No. 1 to Draft Registration Statement on Form F-1 (the “Draft Registration Statement”). Contemporaneously,
we are publicly filing the Registration Statement via Edgar (the “Amended F-1”).

In
order to facilitate the review by the Commission’s staff (the “Staff”) of the Amended F-1, we have responded to the
comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s
comments and correspond to the numbered paragraph in the Staff’s Letter.

Amendment
No. 1 to Draft Registration Statement submitted August 29, 2024

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

Results
of Operations

Comparison
of Results of Operations for the Fiscal Years Ended March 31, 2023 and 2024, page 35

    1.
    You
    state that the 30.4% cost of revenue decrease correlates to the 16.6% decrease in revenue. The decrease in revenues only partially
    explains the cost of revenue decrease. Expand your disclosure to discuss the reasons for the residual 13.8% in cost of revenue. In
    addition, discuss the changes in cost of revenues on a dollar basis.

  Response: The Company
  has revised the disclosures on pages 36 of the Amended F-1 in response to the Staff’s comment.

    2.
    In
    your discussion of general and administrative expense, disclose the underlying reasons why “back-end payroll” increased
    in the fiscal year ended March 31, 2024.

  Response: The
  Company has revised the disclosures on page 36 of the Amended F-1 in response to the Staff’s comment.

Revenue,
page 36

    3.
    We
    note your disclosure that your decrease in revenue for the fiscal year ended March 31, 2024 was intensified by the Russia-Ukraine
    conflict but offset by a post-COVID economic recovery. Please revise to provide more detailed disclosure regarding the impact of
    the Russia-Ukraine conflict on your revenues. In this regard, we note your disclosure on page 34 describing how regional conflicts
    and geopolitical tensions, such as the Russia-Ukraine conflict, pose significant risks to maritime operations and can impact the
    Company’s revenue.

  Response: The
  Company has revised the disclosures on page 36 of the Amended F-1 in response to the Staff’s comment.

Management

Other
Corporate Governance Matters, page 68

    4.
    You
    disclose here that you may in the future be eligible to utilize the controlled company exemptions under the NYSE American corporate
    governance rules if more than 50% of your voting power is held by an individual, a group or another company, and you do not currently
    expect that more than 50% of your voting power will be held by an individual, a group or another company immediately following the
    consummation of this offering. However, the disclosure in your post-offering ownership structure diagram on page 6 as well as your
    risk factor disclosure on page 17 indicate that your “Major Shareholders,” namely Ho Ying Keat Lowell, Andresian D’Rozario,
    Francis Junior James, Randy Yong Choon Hong, and Quah Choong Hua, will collectively own a majority of the combined voting power of
    your ordinary shares. Please advise or revise to address this apparent inconsistency.

  Response: The Company
  has revised the disclosures on page 68 of the Amended F-1 in response to the Staff’s comment.

Financial
Statements, page F-1

    5.
    We
                                            note your response to prior comments nine and ten indicating that you have relied upon the
                                            guidance in FASB ASC 805-50-45 in preparing your financial statements, which depict Vantage
                                            Cayman as a consolidated entity as of March 31, 2024, including the accounts of Vantage BVI,
                                            Vantage Singapore and Vantage Dubai for all periods. However, you have disclosures on pages
                                            5, 44, F-7 and F-8 indicating that Vantage Cayman and Vantage BVI did not exist until April
                                            2, 2024, after the periods covered by your financial statements, also indicating that your
                                            reorganization is not yet complete, e.g. within the explanatory note in advance of page one,
                                            and the statement on F-7 indicating it is estimated to be completed by the end of 2024.

    If
    you have properly identified the reorganization transactions as involving entities under common control, the accounting guidance
    that you have referenced would not be initially applicable until you are preparing financial statements that include the period of
    the reorganization. Therefore, unless the reorganization will be completed prior to the effective date of your registration statement,
    and unless you will update your financial statements to include the period during which the reorganization has been completed prior
    to the effective date, you will need to include separate financial statements of Vantage Cayman, as previously advised.

    In
    either case the disclosures on pages F-7 and F-8 should be revised to accurately describe the basis of presentation, to include differentiating
    between the terms combined and consolidated, when describing the basis of presentation for periods before and after the date of completing
    the reorganization, respectively, i.e. your use of these terms should correlate with the ownership structure in place during the
    periods covered by the financial statements. We reissue prior comments nine and ten.

  Response: The Company
  has revised the references of “Consolidated Financial Statements” to “Combined Financial Statements” throughout
  the Amended F-1. Disclosures on pages F-7 and F-8 have also been revised to describe the basis of presentation as reorganization transactions
  involving entities under common control.

    6.
    Given
    your various disclosures indicating that Vantage Dubai was not formed until June 20, 2023, please expand your disclosures on page
    F-7 and F-8 to identify the owners who initiated and completed its formation, also to describe their rationale, and to explain how
    that formation event has been depicted in your combined financial statements. Please further clarify that its operations are fully
    included within the combined financial statements from the date of its formation if true.

  Response: The
  Company has revised the disclosures on pages F-7 and F-8 of the Amended F-1 in response to the Staff’s comment.

1.
Organization and Principal Activities

Reorganization,
page F-7

    7.
    We
                                            understand from your response to prior comment 14 that you intend to change the ownership
                                            of Vantage Singapore and Vantage Dubai prior to completing the reorganization and that this
                                            effort will result in three individuals collectively owning more than 50% of the voting interests
                                            of each entity. You identify this result as the rationale for characterizing the reorganization
                                            as a transaction among entities under common control and for presenting the accounts of both
                                            entities on a combined basis in the financial statements. You indicate that you have not
                                            provided all of the information requested in our comment as you are still in the process
                                            of preparing for the reorganization.

    However,
the illustrations on pages 6 and 45 indicate the three individuals mentioned in your response will collectively own 40.68%, rather than
more than 50%, of the consolidated entity, and you have disclosure in the second-to-last paragraph on page 68, indicating that you do
not expect there to be a control group following the offering.

    If
    you are not able to show that Vantage Singapore and Vantage Dubai were under common control during the 2023 and 2024 fiscal years,
    please replace the combined financial statements with separate financial statements for each entity as the retrospective treatment
    applied in depicting a common control transaction would be limited to the periods during which the entities were actually under common
    control, as indicated in FASB ASC 805-50-45-5. We reissue prior comment 14.

  Response: The Company
  has revised the disclosures on pages 68 and F-7 of the Amended F-1 in response to the Staff’s comment.

  The five controlling shareholders
  (namely Andresian D’Rozario, Francis Junior James, Ho Ying Keat Lowell, Randy Yong Choon Hong and Quah Choong Hua) of
  Vantage Singapore have entered into an acting-in-concert deed, which outlines their commitment to vote and act together in a manner
  that establishes their collective control over Vantage Singapore. This an acting-in-concert deed is being filed with the Amended F-1
  as Exhibit 10.2. Additionally, Vantage Dubai is controlled 100% by Andresian D’Rozario, Randy Yong Choon Hong and Quah Choong
  Hua, who are also the common shareholders of Vantage Singapore, thereby establishing common control over both Vantage Singapore and
  Vantage Dubai in accordance with the relevant accounting standards.

    8.
    Please
                                            revise your disclosure describing the reorganization as involving “…the transfer
                                            of 100% of the equity interests in Vantage Singapore and Vantage Dubai from its original
                                            shareholders, Vantage Singapore and Vantage Dubai to Vantage BVI” as necessary to identify
                                            the original shareholders of Vantage Singapore and Vantage Dubai rather than suggest the
                                            entities were the shareholders of the entities.

    Please
also revise the illustrations showing the corporate structure prior to the reorganization on pages 6 and 45, to show the ownership of
Vantage Singapore and Vantage Dubai prior to their conveyance of Vantage BVI, since that event is considered part of the reorganization.
For example, it appears that this would include identifying the ownership interests held by the five individuals and the minority interest
group of shareholders in each of Vantage Singapore and Vantage Dubai.

    Please
    disclose the manner by which the conveyance to Vantage BVI either has occurred or will occur, and the manner by which the conveyance
    of Vantage BVI to Vantage Cayman has occurred or will occur, including the dates of conveyance if applicable.

  Response: The
  Company has revised the disclosures on pages 6, 45, F-7 and F-8 of the Amended F-1 in response to the Staff’s
  comment.

Notes
to Consolidated Financial Statements

10.
Shareholders’ Equity, page F-20

    9.
    We note that you report having just one Class B Ordinary Share outstanding
    as of March 31, 2024, March 31, 2023, and April 1, 2022. However, since you previously reported having 450,000 Ordinary Shares outstanding
    as of March 31, 2023 and April 1, 2022, please expand your disclosures to explain the apparent change in your capital structure and
    the apparent conversion of the Ordinary Shares to a Class B Ordinary Share. Please also expand your disclosures to address the following
    points.

    ●

                                                         Given that your 2024 statement of cash flows includes “Proceeds from issuance of ordinary share” of $136,105, and your equity statement includes a corresponding “Issuance of ordinary shares,” explain why you do not report any change in the number of ordinary shares in conjunction with this transaction.

    ●
    Given that you have presented the accounts of Vantage Singapore and Vantage
    Dubai on a combined basis, clarify whether the Class B Ordinary Share was issued by one of these entities or whether you are depicting
    a subsequent change in the capital structure retrospectively, and explain how the individual interests of the five shareholders and
    group of minority shareholders identified on pages 6 and 45 are represented with just one Class B Ordinary Share, if true.

  Response: As
  of March 31, 2023, the Company mistakenly reported having 450,000 Ordinary Shares outstanding. The correct disclosure is that there
  was only one Class B Ordinary Share outstanding as of March 31, 2024, March 31, 2023, and April 1, 2022, prior to the restructuring.
  We acknowledge this error and will ensure that future disclosures accurately reflect this information.

  The “Proceeds from
  issuance of ordinary shares” of S$136,105 in our 2024 statement of cash flows and the corresponding “Issuance of ordinary
  shares” in our equity statement pertain to the initial paid-up capital for the incorporation of Vantage Dubai in June 2023.

13.
Other Income, page F-23

    10.
    We
    note that your gains from “Write-back of allowance for expected credit loss on trade receivable” is included in the other
    income line item, which is presented below the the line on your income statement. Tell us why this is presented within the non-operating
    section of your income statement rather than within operating. Also tell us where you record expected credit loss on accounts receivable
    on your income statement. We would expect both of these related items to be recorded on the same income statement line item within
    operating. If this is not the case, please provide us your basis in GAAP for your presentation.

  Response: The Company
  has revised the disclosures on pages 33, 35, 36, F-4, F-23 of the Amended F-1 in response to the Staff’s comment.

  We have revised
  the disclosure by relocating the “Write-back of allowance for expected credit losses on trade receivables” from other income
  to a deduction under “General and Administrative Expenses.” The expected credit loss on accounts receivable is classified
  as an operating expense within the “General and Administrative Expenses” section of our income statement. Both of these
  related items will be recorded on the same line item within the operating section of our income statement.

16.
Concentration of Risks, page F-24

    11.
    You
    disclose that two vendors accounted for 46.4% and 24.8% of commissions expenses for the year ended March 31, 2024 and that two vendors
    accounted for 26.5% and 19.4% of total commission expenses. Please disclose here and on page 42 the total amount of commissions expense
    for each year. In addition, disclose the line item on the income statement in which commissions expense is included.

  Response: The Company
  has revised the disclosures on pages 42 and F-25 of the Amended F-1 in response to the Staff’s comment.

Please
reach Lawrence Venick, the Company’s outside counsel at +852.5600.0188 if you would like additional information with respect to
any of the foregoing. Thank you.

Sincerely,

    /s/
    Andresian D’Rozario

    Andresian
    D’Rozario

    Vantage
    Corp

    Chief
    Executive Officer

    Encl.

September 26, 2024
Andresian D’Rozario
Chief Executive Officer and Chairman of the Board
Vantage Corp (Singapore)
#05-06, Level 5, 51 Cuppage Road
Singapore 229469
Re:Vantage Corp (Singapore)
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted August 29, 2024
CIK 0002027160
Dear Andresian D’Rozario:
            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
July 23, 2024 letter.
Amendment No. 1 to Draft Registration Statement submitted August 29, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Comparison of Results of Operations for the Fiscal Years Ended March 31, 2023 and 2024, page
35
1.You state that the 30.4% cost of revenue decrease correlates to the 16.6% decrease in
revenue.  The decrease in revenues only partially explains the cost of revenue decrease.
Expand your disclosure to discuss the reasons for the residual 13.8% in cost of revenue.
In addition, discuss the changes in cost of revenues on a dollar basis.
2.In your discussion of general and administrative expense, disclose the underlying reasons
why "back-end payroll" increased in the fiscal year ended March 31, 2024.

September 26, 2024
Page 2
Revenue, page 36
3.We note your disclosure that your decrease in revenue for the fiscal year ended March 31,
2024 was intensified by the Russia-Ukraine conflict but offset by a post-COVID
economic recovery. Please revise to provide more detailed disclosure regarding the impact
of the Russia-Ukraine conflict on your revenues. In this regard, we note your disclosure
on page 34 describing how regional conflicts and geopolitical tensions, such as the
Russia-Ukraine conflict, pose significant risks to maritime operations and can impact the
Company’s revenue.
Management
Other Corporate Governance Matters, page 68
4.You disclose here that you may in the future be eligible to utilize the controlled company
exemptions under the NYSE American corporate governance rules if more than 50% of
your voting power is held by an individual, a group or another company, and you do not
currently expect that more than 50% of your voting power will be held by an individual, a
group or another company immediately following the consummation of this
offering. However, the disclosure in your post-offering ownership structure diagram on
page 6 as well as your risk factor disclosure on page 17 indicate that your "Major
Shareholders," namely Ho Ying Keat Lowell, Andresian D’Rozario, Francis Junior James,
Randy Yong Choon Hong, and Quah Choong Hua, will collectively own a majority of the
combined voting power of your ordinary shares. Please advise or revise to address this
apparent inconsistency.
Financial Statements, page F-1
We note your response to prior comments nine and ten indicating that you have relied
upon the guidance in FASB ASC 805-50-45 in preparing your financial statements, which
depict Vantage Cayman as a consolidated entity as of March 31, 2024, including the
accounts of Vantage BVI, Vantage Singapore and Vantage Dubai for all periods.
However, you have disclosures on pages 5, 44, F-7 and F-8 indicating that Vantage
Cayman and Vantage BVI did not exist until April 2, 2024, after the periods covered by
your financial statements, also indicating that your reorganization is not yet complete, e.g.
within the explanatory note in advance of page one, and the statement on F-7 indicating it
is estimated to be completed by the end of 2024.

If you have properly identified the reorganization transactions as involving entities under
common control, the accounting guidance that you have referenced would not be initially
applicable until you are preparing financial statements that include the period of the
reorganization.  Therefore, unless the reorganization will be completed prior to the
effective date of your registration statement, and unless you will update your financial
statements to include the period during which the reorganization has been completed prior
to the effective date, you will need to include separate financial statements of Vantage
Cayman, as previously advised.

In either case the disclosures on pages F-7 and F-8 should be revised to accurately
describe the basis of presentation, to include differentiating between the terms combined 5.

September 26, 2024
Page 3
and consolidated, when describing the basis of presentation for periods before and after
the date of completing the reorganization, respectively, i.e. your use of these terms should
correlate with the ownership structure in place during the periods covered by the financial
statements.  We reissue prior comments nine and ten.
6.Given your various disclosures indicating that Vantage Dubai was not formed until June
20, 2023, please expand your disclosures on page F-7 and F-8 to identify the owners who
initiated and completed its formation, also to describe their rationale, and to explain how
that formation event has been depicted in your combined financial statements.  Please
further clarify that its operations are fully included within the combined financial
statements from the date of its formation if true.
1. Organization and Principal Activities
Reorganization, page F-7
7.We understand from your response to prior comment 14 that you intend to change the
ownership of Vantage Singapore and Vantage Dubai prior to completing the
reorganization and that this effort will result in three individuals collectively owning more
than 50% of the voting interests of each entity. You identify this result as the rationale for
characterizing the reorganization as a transaction among entities under common control
and for presenting the accounts of both entities on a combined basis in the financial
statements. You indicate that you have not provided all of the information requested in
our comment as you are still in the process of preparing for the reorganization.

However, the illustrations on pages 6 and 45 indicate the three individuals mentioned in
your response will collectively own 40.68%, rather than more than 50%, of the
consolidated entity, and you have disclosure in the second-to-last paragraph on page 68,
indicating that you do not expect there to be a control group following the offering.

If you are not able to show that Vantage Singapore and Vantage Dubai were under
common control during the 2023 and 2024 fiscal years, please replace the combined
financial statements with separate financial statements for each entity as the retrospective
treatment applied in depicting a common control transaction would be limited to the
periods during which the entities were actually under common control, as indicated in
FASB ASC 805-50-45-5. We reissue prior comment 14.
Please revise your disclosure describing the reorganization as involving “…the transfer of
100% of the equity interests in Vantage Singapore and Vantage Dubai from its original
shareholders, Vantage Singapore and Vantage Dubai to Vantage BVI” as necessary to
identify the original shareholders of Vantage Singapore and Vantage Dubai rather than
suggest the entities were the shareholders of the entities.

Please also revise the illustrations showing the corporate structure prior to the
reorganization on pages 6 and 45, to show the ownership of Vantage Singapore and
Vantage Dubai prior to their conveyance of Vantage BVI, since that event is considered
part of the reorganization. For example, it appears that this would include identifying the
ownership interests held by the five individuals and the minority interest group of
shareholders in each of Vantage Singapore and Vantage Dubai.
 8.

September 26, 2024
Page 4
Please disclose the manner by which the conveyance to Vantage BVI either has occurred
or will occur, and the manner by which the conveyance of Vantage BVI to Vantage
Cayman has occurred or will occur, including the dates of conveyance if applicable.
Notes to Consolidated Financial Statements
10. Shareholders' Equity, page F-20
9.We note that you report having just one Class B Ordinary Share outstanding as of March
31, 2024, March 31, 2023, and April 1, 2022. However, since you previously reported
having 450,000 Ordinary Shares outstanding as of March 31, 2023 and April 1, 2022,
please expand your disclosures to explain the apparent change in your capital structure
and the apparent conversion of the Ordinary Shares to a Class B Ordinary Share. Please
also expand your disclosures to address the following points.

•Given that your 2024 statement of cash flows includes “Proceeds from issuance of
ordinary share” of $136,105, and your equity statement includes a corresponding
“Issuance of ordinary shares,” explain why you do not report any change in the
number of ordinary shares in conjunction with this transaction.

•Given that you have presented the accounts of Vantage Singapore and Vantage Dubai
on a combined basis, clarify whether the Class B Ordinary Share was issued by one of
these entities or whether you are depicting a subsequent change in the capital
structure retrospectively, and explain how the individual interests of the five
shareholders and group of minority shareholders identified on pages 6 and 45 are
represented with just one Class B Ordinary Share, if true.
13. Other Income, page F-23
10.We note that your gains from "Write-back of allowance for expected credit loss on trade
receivable" is included in the other income line item, which is presented below the the line
on your income statement.  Tell us why this is presented within the non-operating section
of your income statement rather than within operating.  Also tell us where you
record expected credit loss on accounts receivable on your income statement.  We would
expect both of these related items to be recorded on the same income statement line item
within operating.  If this is not the case, please provide us your basis in GAAP for your
presentation.

16. Concentration of Risks, page F-24
11.You disclose that two vendors accounted for 46.4% and 24.8% of commissions expenses
for the year ended March 31, 2024 and that two vendors accounted for 26.5% and 19.4%
of total commission expenses.  Please disclose here and on page 42 the total amount of
commissions expense for each year.  In addition, disclose the line item on the income
statement in which commissions expense is included.
            Please contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Yong Kim, Staff
Accountant, at 202-551-3323 if you have questions regarding comments on the financial

September 26, 2024
Page 5
statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at 202-
551-6548 or Daniel Morris, Legal Branch Chief, at 202-551-3314 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Lawrence Venick, Esq.

July 23, 2024
Andresian D’Rozario
Chief Executive Officer and Chairman of the Board
Vantage Corp (Singapore)
#05-06, Level 5, 51 Cuppage Road
Singapore 229469
Re:Vantage Corp (Singapore)
Draft Registration Statement on Form F-1
Submitted June 25, 2024
CIK 0002027160
Dear Andresian D’Rozario:
            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.
Draft Registration Statement on Form F-1
Prospectus Summary
Our Corporate Structure and History, page 6
1.Please revise to also include a diagram of your ownership structure prior to your
reorganization.
Corporate Information, page 7
Your emerging growth company (“EGC”) disclosures are unclear and
inconsistent. Specifically, we noted the following:

•At the bottom of page 7 you state that you have “irrevocably elected not to avail”
yourselves of the extended transition period for adopting new or revised accounting
statements. This disclosure suggests you will opt out of Section 107 provisions.
 2.

July 23, 2024
Page 2
•In the risk factor “We are an emerging growth company within the meaning of the
Securities Act and may take advantage of certain reduced reporting requirements” on
page 22, you state that you do not plan to “opt out” of such exemptions, and, as a
result of your election, your financial statements may not be comparable to those of
companies that comply with public company effective dates. This disclosure suggests
you will take advantage (opt in) of the Section 107 provisions.

Please address the following comments:

•Clearly disclose whether you plan to take advantage of (opt in) or opt out of, the
Section 107 provisions which provide EGCs an extended transition period to comply
with new or revised accounting standards.

•If you elect to take advantage of (opt in) the extended transition period, continue to
disclose that your financial statements may not be comparable to those that comply
with public company effective dates.

•If you elect to opt out of the extended transition period, check the appropriate box on
the cover page for this election.

•On page 7, you reference “standards required by the IASB” despite reporting under
US GAAP. Revise as appropriate.
Market and Industry Data, page 8
3.You disclose here that your prospectus includes statistical and other industry and market
data that you obtained from industry publications and research, surveys and studies
conducted by third parties, as well estimates by our management based on such data.
Please revise to clarify that you commissioned the "Shipbroking Market Report 2023-
2027” issued in December 2022 from Technavio to provide information cited in your
prospectus regarding your industry and market position.
Risk Factors
We face risks of potential unauthorized use and limited legal protection, page 13
4.Please revise here and under Intellectual Property at page 58 to clarify whether you or any
other person or entity owns intellectual property rights in Opswiz. In addition, please
disclose the size of the grant from Enterprise Singapore in U.S. dollars and whether
portions of the proceeds of this offering will be used to further develop the Opswiz
system.
You may face difficulties in protecting your interests as a shareholder, as Cayman Islands law
provides substantially less protection, page 26
5.We note your disclosure on page 104 that all of your directors and executive officers are
residents outside the United States. Please expand your disclosure here and in your
enforcement of civil liabilities section to discuss the ability of U.S. investors to
effect service of process within the United States on your directors and officers.

July 23, 2024
Page 3
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Global oil tanker fleet production and scrapping , page 35
6.We note your disclosure that changes in vessel technology, regulations, and
environmental standards can impact vessel utilization rates and operating costs, further
affecting the Company’s revenue. If material, please revise to include a discussion of the
regulations and environmental standards that could impact your business operations
and revenue, and add related risk factor disclosure if appropriate.
Liquidity and Capital Resources
Concentration and Credit Risks, page 42
7.We note your disclosure that, as of March 31, 2023, one vendor accounted for 68.1% of
your account payables. Please revise to provide a more detailed description of your
relationship with this vendor, including which types of products or services are supplied,
and whether such relationship involves long term agreements or arrangements. Please
describe the material terms of any such agreements or arrangements. To the extent you
are substantially dependent on any agreement or arrangement with this vendor,
include the agreement as an exhibit. If you believe you are not substantially dependent on
the agreements, please explain why. Refer to Item 8(a) of Form F-1 and Item 601(b)(10)
of Regulation S-K.
Industry Overview, page 46
8.We note your disclosure that the information presented in this section has been derived
from the “Shipbroking Market Report 2023-2027” commissioned by you and issued in
December 2022 by Technavio to provide information regarding your industry and market
position. Please include a consent from Technavio pursuant to Rule 436 of the Securities
Act as an exhibit.  Also, since this report was issued in December 2022, advise on
whether you have given any consideration to updating this report.
Financial Statements, page F-1
9.Please present audited financial statements of the Registrant, Vantage Corp. At a
minimum, an audited balance sheet is required. If Vantage Corp has commenced
operations, audited statements of comprehensive income, stockholders’ equity and cash
flows for the period from the date of inception to the date of the audited balance sheet also
are required. In addition, address the presentation of Vantage BVI in the notes to the
audited financial statements.  Refer to Item 4 of Form F-1 and Item 8 of Form 20-F.
You present financial statements of "Vantage Corp and its Subsidiaries"; however,
Vantage Corp was not in existence on March 31, 2023 or 2024. Accordingly, the labeling
of your financial statements is inappropriate.

It appears that the financial statements prior to the reorganization (as of and for the years
ended March 31, 2023 and 2024) represent  combined  financial statements of Vantage
Shipbrokers Pte. Ltd. ("Vantage Singapore") and "Vantage Nexus Commercial Brokers
Co. L.L.C. ("Vantage  Dubai") and financial statements that will be presented after the
reorganization will be consolidated  financial statements of Vantage Corp, which will
include Vantage (BVI) Corporation ("Vantage BVI"), Vantage Singapore and Vantage 10.

July 23, 2024
Page 4
Dubai.

If this is the case, please make appropriate changes to the financial statements including,
but not limited to:

•the labeling of your financial statements
•reorganization disclosure on page F-7
•consolidation policy on page F-7

In addition, please have your auditors make any necessary changes to their audit opinion.
Consolidated Statements of Operations and Comprehensive Income, page F-4
11.We note your presentation of gross profit on the face of your statement of operations and
comprehensive income. We also note that you recorded $167,612 of depreciation and
amortization in the year ended December 31, 2023 and that $28,634 relates to
depreciation of plant and equipment that is recorded within the general and administrative
expense line item. Please confirm that gross profit reflects all costs that are allocable to
costs of revenues in accordance with GAAP, including the allocable portion of
depreciation and amortization, or, revise as appropriate.

If you do not believe a depreciation and amortization should be included within cost of
revenues, explain the basis for your conclusion and tell us how your presentation complies
with SAB Topic 11:B.

Furthermore, in  your footnotes, please present a description of gross profit, discuss the
assets that are being amortized, disclose the amount of amortization expense recorded,
and disclose the line item(s) on the income statement in which amortization is recorded.
Consolidated Statements of Cash Flows, page F-6
12.We note your line items "Interest Expenses on Lease Liabilities" within the operating
activities section of your statement of cash flows, and, "Principal Payment of Lease
Liabilities" and "Payment of Interest on Lease Liabilities" within financing
activities. Since it appears that you have only operating leases, explain how your
presentation complies with ASC 842-20-45-5 or revise as necessary.
13.We note your presentation of "Interest Income" as an adjustment to cash provided by
operating activities and the corresponding "Interest Received" line item presented as a
cash inflow from investing activities. Please explain how your presentation complies with
ASC 230. If this represents cash receipts from interest, please refer to the guidance in
ASC 230-10-45-16.b and revise as necessary.
1. Organization and Principal Activities
Reorganization, page F-7
You state that the reorganization will be accounted for as a business combination among
entities under common control. Refer to ASC 805-50-15-6 and tell us how you 14.

July 23, 2024
Page 5
determined the reorganization meets the scope of a transaction between entities under
common control. In doing so, tell us why you believe you assert control as it appears that
the entities are owned by several shareholders. If the shareholders’ are operating together
to assert common control, provide us with any agreements or summarize
arrangements made between the shareholders that stipulate all shareholders will vote and
act together in such manner that they can be viewed as entities under common control or
under common management. Finally, please provide us with a list of shareholders and
ownership percentages for each of your entities prior to the reorganization.
Notes to Consolidated Financial Statements, page F-7
15.Given the significance of your "Other Income" line item, please describe and quantify the
items that are included within this line item in the notes to your financial statements,
preferably in a separate footnote.
2. Summary of Significant Accounting Policies
(q) Government Grant, page F-12
16.Please present the disclosures required by ASC 832-10-50, including a general description
of the government grant transaction(s), the line item(s) on the income statement and
balance sheet that are affected by such transactions, the amounts applicable to each line
item, and any significant terms or conditions of the government grants.
11. Revenue by Service, page F-17
17.You state on page 50 that you divide the services you provide to the tanker market into
the following five divisions:

•Dirty petroleum products
•Clean petroleum products
•Petrochemicals
•Biofuels and vegetable oils
•Projects

We also note that each of your five divisions is overseen by a dedicated division head who
is responsible for managing the brokers within their division. Please tell us how you
considered presenting disaggregated revenue disclosures under ASC 606-10-50-5 for your
five divisions.
General
18.You refer to your financials statements as "Consolidated Financial Statements",
"Combined Financial Statements" and "Consolidated Combined Financial Statements" in
your filing. Please present the description of your financial statements in a consistent
manner. Alternatively, you may want to describe the financial statements presented prior
to the reorganization, and the financial statements that will be presented subsequent to the
reorganization.
Please provide us with supplemental 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, 19.

July 23, 2024
Page 6
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not they retained or intend to retain copies of the
communications. Please contact the staff member associated with the review of this filing
to discuss how to submit the materials, if any, to us for our review.
            Please contact Joseph Klinko, Staff Accountant, at 202-551-3824, or Yong Kim, Staff
Accountant, at 202-551-3323 if you have questions regarding comments on the financial
statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at 202-
551-6548 or Daniel Morris, Legal Branch Chief, at 202-551-3314 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Lawrence Venick, Esq.