CORRESP 1 filename1.txt (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