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                                                            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

2.     We note your response to prior comment 5 and refer you to comment 9 in
our July 23,
 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.
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