Exhibit 8.1

Future Yield Holdings Limited CEDE & Co Chung Mei Investment Limit A APAC (Holdings) GROUP Corp Chardan Capital Markets LLC Corporate shareholders* 7.39% 26.75% 2.56% 6.45% 15.46% John Ignatius Brebeck Hoang Giang Nguyen Abuzzal Abusaeri Hok Lun Alan Lau Hei Yue Tina Fong Wing Fung Alfred Siu Individual shareholders* 0.20% 0.20% 0.20% 0.34% 22.92% 17.53% Listing Company Previously name, A SPAC I Mini Acquisition Corp, renamed to NewGenIvf Group Ltd on April 3, 2024 (BVI) # 100% Unlisted holding company NewGenivf Limited (Cayman) 0.01% 100% 100% 100% 100% 100% Incorporation and Operating entity^ FFPGS (HK) Ltd [Holding 100%] (Incorporated in HK on Deccember 19, 2019 Marketing and administrative services First Fertility Phnom Penh Ltd [Holding 100%] Incorporated in Cambodia on August 10, 2015 Provision of IVF treatment First Fertility Bishkek LLC [Holding 100%] Incorporated in Kyrgyzstan on October 11, 2019 Provision surrogacy and ancillary caring services Well Image Limited [100%] Incorporated in HK on July 11, 2008 Investment Holding Sunipa Tanalckapat 51% 48.90% 49% Med Holdings Limited [Holding 49%] Incorporated in Thailand on January 21, 2015 Investment holding 50.99% *: Share holders and share holding % is reference up to May 17, 2024, provided by Secretarial services company, Stephen Stone # : A SPAC I Mini Acquisition Corp, was named "NewGenIvf Group Limited" on April 3, 2024 and its shares is listed on the Nasdaq Capital Market under the tickers "NIVF". ^ : Company incorporation and business activity is reference to auditor report, provided by One - stop at May 14, 2024 First Fertility PGS Center Co Ltd [Holding 74%] Incorporated on March 6, 2014 Provision of IVF treatment