July 15, 2019

K. T. Ong
Chief Financial Officer
Vitaxel Group Ltd
Wisma Ho Wah Genting, No. 35
Jalan Maharajalela, 50150
Kuala Lumpur, Malaysia

       Re: Vitaxel Group Ltd
           Form 10-K for Fiscal Year Ended December 31, 2018
           File No. 000-55685

Dear Mr. Ong :

       We have limited our review of your filing to the financial statements
and related
disclosures 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. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 31, 2018

ITEM 9A. Controls and Procedures, page 18

1.    You conclude that your disclosure controls and procedures were not
effective. However,
      in your conclusion of Management's Annual Report on Internal Control over
Financial
      Reporting, you conclude that "the control deficiency over financial
reporting identified
      during the previous period has been remediated and the disclosure
controls and procedures
      were effective as of December 31, 2018." Please advise as to whether your
disclosure
      controls and procedures and internal control over financial reporting
were effective or not
      effective and amend your filing accordingly. Please see Items 307 and 308
of Regulation
      S-K.
       In closing, 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.
 K. T. Ong
Vitaxel Group Ltd
July 15, 2019
Page 2

       You may contact Melissa Raminpour, Accounting Branch Chief, at (202)
551-3379 with
any questions.



                                                       Sincerely,
FirstName LastNameK. T. Ong
                                                       Division of Corporation
Finance
Comapany NameVitaxel Group Ltd
                                                       Office of Transportation
and Leisure
July 15, 2019 Page 2
cc:       Mark Crone
FirstName LastName