EXHIBIT 8.1

SUBSIDIARIES OF CHINA SOUTHERN AIRLINES COMPANY LIMITED

The particulars of the Company’s principal subsidiaries as of December 31, 2006 are as follows:

NAME OF COMPANY	PLACE AND DATE OF ESTABLISHMENT/ OPERATION
Guangxi Airlines Company Limited (a)	PRC
	April 28, 1994
Southern Airlines (Group) Shantou	PRC
Airlines Company Limited (a)	July 20, 1993
Zhuhai Airlines Company Limited (a)	PRC
	May 8, 1995
Xiamen Airlines	PRC
Company Limited (a)	August 11, 1984
Guizhou Airlines	PRC
Company Limited (a)	November 12, 1991
Guangzhou Nanland Air	PRC
Catering Company Limited (b)	November 21, 1989
Guangzhou Baiyun International Logistic Company Ltd (a)	PRC
	July 23, 2002
China Southern West Australian	Australia
Flying College Pty Limited	January 26, 1971
Xinjiang Civil Aviation	PRC
Property Management Limited (a)	December 12, 2002
Guangzhou Air Cargo	PRC
Company Limited (a)	March 31, 2004

(a)	These subsidiaries are PRC limited companies.
(b)	This subsidiary is a Sino-foreign equity joint venture company.