United States securities and exchange commission logo
May 17, 2022
Anna Rudensj
General Counsel
Polestar Automotive Holding UK Ltd
Assar Gabrielssons V g 9
405 31 G teborg, Sweden
Re: Polestar Automotive
Holding UK Ltd
Amendment No. 6 to
Registration Statement on Form F-4
Filed May 9, 2022
File No. 333-260992
Dear Ms. Rudensj :
We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
otherwise, our references to prior comments are to comments in our May
5, 2022 letter.
Amendment No. 6 to Registration Statement on Form F-4
Audited Financial Statements of Polestar Automotive Holding Limited
Revenue recognition, page F-42
1. We note from your
response to prior comment 3 that for the year-ended December 31,
2021, Polestar did not
make a material amount of true-up payments to BANA beyond the
initial Enhancement
payments made when the leases were originated. To the extent there
are material changes to
your true-up payments (i.e. increases or decreases) in future
periods, please
disclose such amounts accordingly.
You may contact Eiko Yaoita Pyles, Staff Accountant, at (202)
551-3587 or Jean Yu,
Assistant Chief Accountant, at (202) 551-3305 if you have questions
regarding comments on the
Anna Rudensj
Polestar Automotive Holding UK Ltd
May 17, 2022
Page 2
financial statements and related matters. Please contact Bradley Ecker, Staff
Attorney, at (202)
551-4985 or Sherry Haywood, Staff Attorney, at (202) 551-3345 with any other
questions.
FirstName LastNameAnna Rudensj Sincerely,
Comapany NamePolestar Automotive Holding UK Ltd
Division of
Corporation Finance
May 17, 2022 Page 2 Office of
Manufacturing
FirstName LastName