(SHEARMAN & STERLING LLP LOGO)
(SHEARMAN & STERLING LLP CHINESE LOGO)
2318 CHINA WORLD TOWER TWO | 1 JIANGUOMENWAI DAJIE | BEIJING | 100004
WWW.SHEARMAN.COM | T +8610.6505.3399 | F +8610.6505.1818
RESIDENT PARTNERS
Lee Edwards
Alan D. Seem
Admitted in New York
Writer's Email Address: November 27, 2006
Alan.Seem@shearman.com
Writer's Direct Number:
+86.10.5922.8002
VIA FACSIMILE
- -------------
Ms. Beverly A. Singleton, Staff Accountant
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-3561
Tel: +1.202.551.3328
Fax: +1.202.772.9202
RE: GUANGSHEN RAILWAY COMPANY LIMITED
FORM 20-F FOR FISCAL YEAR ENDED DECEMBER 31, 2005
FILED JUNE 29, 2006
FILE NO. 1-14362
Dear Ms. Singleton:
We have been asked by our client, Guangshen Railway Company Limited
("Guangshen"), to confirm that they are in receipt of your recent letter
commenting on Guangshen's Form 20-F for the fiscal year ended December 31, 2005.
While Guangshen's management has devoted significant resources to ensure the
timely responses to the comments from the Staff and are working diligently to do
so, some of the responses by their nature will require a significant amount of
time and effort. Therefore, Guangshen has asked us to request on their behalf an
extension of the deadline for responding to December 15, 2006. Guangshen would
be grateful if the Staff could accommodate this request.
* * * *
Please direct any questions concerning this letter to the undersigned at
+86.10.5922.8002.
Very truly yours,
/s/ Alan Seem
-------------
Alan Seem
cc: Margery E. Reich, Senior Staff Accountant
David R. Humphrey, Branch Chief
Securities and Exchange Commission
Mr. Yao Xiaocong
Mr. Guo Xiangdong
Guangshen Railway Company Limited