CORRESP 2 filename2.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: December 13, 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 refer to our letter dated November 27, 2006 in which we requested on behalf of our client, Guangshen Railway Company Limited ("Guangshen"), for an extension of the deadline for responding to your letter commenting on Guangshen's Form 20-F for the fiscal year ended December 31, 2005. Guangshen's management has continued to devote significant resources to respond to the comments from the Staff and some of the responses require further work, including discussions with Guangshen's reporting accountants, to ensure the Staff's concerns are properly addressed. Therefore, Guangshen has asked us to request on their behalf a further extension of the deadline for responding to Janaury 15, 2007. 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