EX-8.1

Exhibit 8.1

June 29, 2023

BioPlus Acquisition Corp.

260 Madison Avenue

Suite 800

New York, New York 10026

Ladies and Gentlemen:

We have acted as counsel to BioPlus Acquisition Corp., a Cayman Islands exempted company (“BIOS”) in connection with the transactions contemplated by the Business Combination Agreement and Plan of Reorganization, dated as of May 2, 2023 (as amended or modified from time to time, the “Merger Agreement”), by and among BIOS, Guardian Merger Subsidiary Corp., a Delaware corporation and a direct wholly owned subsidiary of BIOS (“Merger Sub”), Avertix Medical, Inc., (f/k/a Angel Medical Systems, Inc.), a Delaware corporation (“Avertix Medical”), and, solely with respect to Section 3.03(b) and Section 7.21 of the Merger Agreement, BioPlus Sponsor LLC, a Cayman Islands limited liability company, pursuant to which Merger Sub will merge with and into Avertix Medical (the “Business Combination”). Unless otherwise indicated, each capitalized term used herein has the meaning ascribed to it in the Registration Statement (defined below).

Pursuant to the Merger Agreement, assuming the Domestication Proposal is approved, at least one day before the closing of the Business Combination, BIOS will change its jurisdiction of incorporation from the Cayman Islands to the State of Delaware by deregistering as an exempted company in the Cayman Islands and domesticating and continuing as a corporation incorporated under the laws of the State of Delaware (the “Domestication”).

This opinion is being delivered in connection with the Registration Statement (File No. 333-271915) of BIOS on Form S-4, filed with the Securities and Exchange Commission, as amended and supplemented through the date hereof (the “Registration Statement”).

In preparing the opinion set forth below, we have examined and reviewed originals or copies, certified or otherwise identified to our satisfaction, of: (i) the Registration Statement; (ii) the Merger Agreement; (iii) the representation letter of BIOS delivered to us for purposes of this opinion (the “Representation Letter”) and (iv) such other documents, certificates and records as we have deemed necessary or appropriate as a basis for our opinion. In such examination, we have assumed the genuineness of all signatures, the legal capacity of natural persons, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as duplicates or certified or conformed copies, and the authenticity of the originals of such latter documents.

In rendering our opinion, we have assumed, without any independent investigation or examination thereof, that (i) the Domestication will be consummated in the manner described in the Registration Statement and the Business Combination will be consummated in the manner described in the Registration Statement and the Merger Agreement, each will be effective under applicable law, and none of the terms or conditions contained in either the Registration Statement or the Merger Agreement will be waived or modified, (ii) the facts relating to (A) the Domestication are accurately and completely reflected in the Registration Statement and (B) the Business Combination are accurately and completely reflected in the Registration Statement and the Merger Agreement, (iii) any representations made in the Representation Letter are true, complete and correct and will remain true, complete and correct at all times up to and including the effective time of the Domestication and (iv) any representations made in the Representation Letter subject to qualification relating to the knowledge, belief, expectation or intent of any party are true, complete and correct and will remain true, complete and correct at all times up to and including the effective time of the Domestication, in each case, without such qualification. Our opinion assumes and is expressly conditioned on, among other things, the initial and continuing accuracy of the facts, information, covenants, representations and warranties set forth in the documents referred to above.

Our opinion is based on the Internal Revenue Code of 1986, as amended, (the “Code”), Treasury regulations promulgated thereunder, judicial decisions, published positions of the Internal Revenue Service (the “Service”), and such other authorities as we have considered relevant, all as in effect on the date of this opinion and all of which are subject to change or differing interpretations, possibly with retroactive effect. A change in the authorities upon which our opinion is based could affect the conclusions expressed herein. Moreover, there can be no assurance that positions contrary to our opinion will not be taken by the Service or, if challenged, by a court.