Mail Stop 3561

      							August 9, 2005

Mr.  Tong Xudong
Executive Director and Vice President
APT Satellite Holdings Limited
22 Dai Kwai Street
Tai Po Industrial Estate, Tai Po
New Territories, Hong Kong
Tel: 852-26002100
Fax: 852-25220419

	Re:	APT Satellite Holdings Limited
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 29, 2005
      File No. 5-50155

Dear Mr. Xudong:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


Form 20-F for Fiscal Year Ended December 31, 2004

Note 22: Summary of Significant Differences Between Hong Kong and
United States Generally Accepted Accounting Principles and
Additional
Disclosures Required Under US GAAP;
Impairment of long-lived assets; page F-53

1. We note that you recorded a US GAAP adjustment for the
impairment
of property, plant and equipment of HK $1.8 million in 2004.  Tell
us
why you did not record a US GAAP adjustment for the impairment
loss
recognized with respect to communication satellites of HK $129.1
million.

Note 22: Summary of Significant Differences Between Hong Kong and
United States Generally Accepted Accounting Principles and
Additional
Disclosures Required Under US GAAP;
Summarized information on APT Telecom, a significant jointly
controlled entity; page F-61

2. We note impairment losses of HK $89,018 on p. F-61 related to
APT
Telecom, your jointly controlled entity.  As a result of this
impairment charge, it appears you meet the significant income test
under Rule 3-09 of Regulation S-X and therefore you should provide
separate financial statements for APT Telecom.  In accordance with
Rule 3-09 of Regulation S-X, these separate financial statements
are
required to be audited for only those fiscal years in which either
the first or third condition set forth in Rule 1-02 (w) of
Regulation
S-X, substituting 20 percent for 10 percent, is met.  Please
revise
or advise.


*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Dave Walz, Staff Accountant, at (202) 551-
3358
or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-
3835
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

								Sincerely,



								Larry Spirgel
								Assistant Director
??

??

??

??

Mr. Tong Xudong
APT Satellite Holdings Limited
August, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE