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                               July 17, 2023

       Emilio Ca  avate
       Chief Financial Officer
       Turbo Energy, S.A.
       Plaza de Am  rica
       Number 2, 4B
       Val  ncia, Spain 46004

                                                        Re: Turbo Energy, S.A.
                                                            Registration
Statement on Form F-1
                                                            Filed July 11, 2023
                                                            File No. 333-273198

       Dear Emilio Ca  avate:

              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
 Emilio Ca  avate
FirstName  LastNameEmilio Ca  avate
Turbo Energy,  S.A.
Comapany
July       NameTurbo Energy, S.A.
     17, 2023
July 17,
Page  2 2023 Page 2
FirstName LastName
         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,
 Emilio Ca  avate
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,
FirstName LastNameEmilio Ca  avate
                                                           Division of
Corporation Finance
Comapany NameTurbo Energy, S.A.
                                                           Office of
Manufacturing
July 17, 2023 Page 3
cc:        Louis A. Bevilacqua
FirstName LastName