United States securities and exchange commission logo
August 21, 2023
Prashant Aggarwal
Chief Executive Officer
MoneyHero Ltd
70 Shenton Way
#18-15, EON Shenton, S079118
Singapore
Re: MoneyHero Ltd
Amendment No. 2 to
Draft Registration Statement on Form F-4
Submitted August
14, 2023
CIK No. 0001974044
Dear Prashant Aggarwal:
We have reviewed your amended draft registration statement and
have the following
comment. In our comment, we may ask you to provide us with information
so we may better
understand your disclosure.
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 our 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
comment and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-4 submitted
August 14, 2023
Material Tax Considerations, page 250
1. We note your response
to comment 3, including the filing of Exhibit 8.1, and reissue.
Please provide a
revised tax opinion of Skadden, Arps, Slate, Meagher & Flom LLP
which covers the
material federal tax consequences of the transaction to the holders of
Bridgetown's securities
and revise your disclosure accordingly to tailor it to address the
material federal tax
consequences of the transaction to those public investors. We note the
filing of Exhibit 8.1;
however, the tax opinion appears to be focused on the initial merger
qualifying as an F
Reorganization within the meaning of Section 368(a)(1)(F) of the
Internal Revenue Code
of 1986. In light of the requirements of Item 601(b)(8) of
Prashant Aggarwal
MoneyHero Ltd
August 21, 2023
Page 2
Regulation S-K, please revise to discuss the tax consequences to
investors and
representations related to those tax consequences. Please revise this
section and the tax
opinion accordingly.
You may contact Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680 with
any other
questions.
Sincerely,
FirstName LastNamePrashant Aggarwal
Division of
Corporation Finance
Comapany NameMoneyHero Ltd
Office of Trade &
Services
August 21, 2023 Page 2
cc: Joseph Casey
FirstName LastName