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                              September 5, 2023

       Lan Huang
       Chief Executive Officer
       BeyondSpring Inc.
       28 Liberty Street, 39th Floor
       New York , New York 10005

                                                        Re: BeyondSpring Inc.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-38024

       Dear Lan Huang:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 166

   1.                                                   We note your statement
that you reviewed your register of members and public filings
                                                        made by your
shareholders in connection with your required submission under paragraph
                                                        (a). Please
supplementally describe any additional materials that were reviewed and tell us
                                                        whether you relied upon
any legal opinions or third party certifications such as affidavits
                                                        as the basis for your
submission. In your response, please provide a similarly detailed
                                                        discussion of the
materials reviewed and legal opinions or third party certifications relied
                                                        upon in connection with
the required disclosures under paragraphs (b)(2) and (3).
   2.                                                   In order to clarify the
scope of your review, please supplementally describe the steps you
                                                        have taken to confirm
that none of the members of your board or the boards of your
                                                        consolidated foreign
operating entities are officials of the Chinese Communist Party. For
                                                        instance, please tell
us how the board members    current or prior memberships on, or
                                                        affiliations with,
committees of the Chinese Communist Party factored into your
                                                        determination. In
addition, please tell us whether you have relied upon third party
                                                        certifications such as
affidavits as the basis for your disclosure.
 Lan Huang
BeyondSpring Inc.
September 5, 2023
Page 2
3.    We note that your disclosures pursuant to Items 16I(b) use terms such as
  us    or    our.    It
      is unclear from the context of these disclosures whether these terms are
meant to
      encompass you and all of your consolidated foreign operating entities or
whether in some
      instances these terms refer solely to BeyondSpring Inc. Please note that
Item 16I(b)
      requires that you provide disclosures for yourself and your consolidated
foreign operating
      entities, including variable interest entities or similar structures. To
clarify this matter,
      please provide the information required by each subsection of Item 16I(b)
for you and all
      of your consolidated foreign operating entities in your supplemental
response.
          With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
           consolidated foreign operating entities are organized or
incorporated and provide the
           percentage of your shares or the shares of your consolidated
operating entities owned
           by governmental entities in each foreign jurisdiction in which you
have consolidated
           operating entities in your supplemental response. We note that your
list of
           subsidiaries in Exhibit 8.1 appears to indicate that you have
subsidiaries in countries
           outside China.
          With respect to (b)(3), (b)(4), and (b)(5), please provide the
required information for
           you and all of your consolidated foreign operating entities in your
supplemental
           response.
4.    With respect to your disclosure pursuant to Item 16I(b)(5), we note that
you have included
      language that such disclosure is    to our knowledge.    Please
supplementally confirm
      without qualification, if true, that your articles and the articles of
your consolidated
      foreign operating entities do not contain wording from any charter of the
Chinese
      Communist Party.
        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 Kyle Wiley at (202) 344-5791 or Andrew Mew at (202)
551-3377 with
any other questions.



                                                             Sincerely,
FirstName LastNameLan Huang
                                                             Division of
Corporation Finance
Comapany NameBeyondSpring Inc.
                                                             Disclosure Review
Program
September 5, 2023 Page 2
cc:       Deni Li
FirstName LastName