February 28, 2025

Gilberto Tomazoni
Chief Executive Officer
JBS B.V.
Stroombaan 16, 5th Floor
1181 VX, Amstelveen, Netherlands

       Re: JBS B.V.
           Amendment No. 5 to Registration Statement on Form F-4
           Filed January 29, 2025
           File No. 333-273211
Dear Gilberto Tomazoni:

     We have reviewed your amended registration statement and have the
following
comments.

        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.

Amendment No. 5 to Registration Statement on Form F-4
Capitalization, page 70

1.     Refer to the second bullet point at the top of the page and the newly
expanded
       discussion of the January 21, 2025, issuances of 5.950% Senior Notes due
2025 in an
       aggregate principal amount of US$1,000.00 million and 6.375% Senior
Notes due
       2055 in an aggregate principal amount of US$750.0 million, and the use
of net
       proceeds therefrom. We note from disclosure on page 10 the net proceeds
were used
       for general corporate purposes, including the repayment of existing
debt. Please
       disclose the amount of existing debt that was repaid and revise the "as
adjusted"
       column to reflect this transaction, as it appears the "as further
adjusted" column
       instead reflects the transaction. Also refer to newly revised subnote
(4) and tell us why
       you have not reflected the US$187.5 million outstanding balance under
the
       commercial paper program in the "as adjusted" column.
 February 28, 2025
Page 2

Management, page 215

2.     We note disclosure on page 217 that your board of directors has
determined all your
       directors and director nominees, other than two named individuals,
qualify as
       independent under the NYSE rules and the Dutch Corporate Governance
Code. Please
       tell us how you determined that Wesley and Joesley Batista meet these
independence
       requirements, or alternatively revise your disclosure as appropriate.
General

3.     Please update compensation disclosure with respect to the registrant and
JBS S.A. to
       reflect the fiscal year ended December 31, 2024, or alternatively
provide your analysis
       as to why such disclosure is not required pursuant to the applicable
requirements of
       Form F-4 and Form 20-F, including with respect to the persons who will
serve as
       directors and executive officers of the registrant.
        Please contact Beverly Singleton at 202-551-3328 or Claire Erlanger at
202-551-3301
if you have questions regarding comments on the financial statements and
related
matters. Please contact Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek
at 202-551-
3641 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing
cc:   John Vetterli