June 26, 2018

Xiangdong Guo
Deputy General Manager and Company Secretary
Guangshen Railway Company Limited
No. 1052 Heping Road
Luohu District
Shenzhen
People's Republic of China
518010

       Re: Guangshen Railway Company Limited
           Form 20-F for the Year Ended December 31, 2017
           Filed April 26, 2018
           File No. 001-14362

Dear Mr. Guo:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for Fiscal Year Ended December 31, 2017

Note 6 - Fixed Assets, page F-42

1.    We note your disclosure here that at 31 December 2017, the ownership
certificates of
      certain buildings with a carrying value of approximately RMB
1,858,288,000 (2016:
      RMB1,819,505,000) had not been obtained. We also note that after
consultation made
      with your legal counsel, the directors consider that there is no legal
restriction to apply for
      and obtain the ownership certificates of such buildings and it should not
lead to any
      significant adverse impact on your operations.
 Xiangdong Guo
Guangshen Railway Company Limited
June 26, 2018
Page 2
         We also note your disclosure in note 8 that at 31 December 2017, land
use right
         certificates of certain pieces of land with an aggregate carrying
value of approximately
         RMB1,318,686,000 (2016: RMB936,304,000) had not been obtained.

         If there is no legal restriction to apply for and obtain the
ownership/right certificates,
         please tell us why you have not done so. Also tell us what risk, if
any, exists by not
         obtaining the ownership/right certificates. Finally, please tell us
whether you have applied
         for such certificates for these or other buildings/land use rights in
the past and, if so, what
         the outcomes have been.
Notes to the financial statements
Note 18 - Trade Receivables, page F-56

2.       We note your disclosure that at 31 December 2017, trade receivables of
approximately
         RMB1,343,182,000 (2016: RMB847,085,000) were past due but not
impaired. Based on
         the aging table provided, these receivables relate to transportation
provided one to four
         years ago and the past due amounts have increased since 2016. You
state there "had"
         been continuous businesses transactions carried out with these
customers and there "was"
         continuous repayment made and no history of default. Please clarify
this statement for us
         to explain whether these customers continue to pay these past due
amounts and tell us how
         much of the 31 December 2017 past due balance has been collected to
date.

         Please also tell us how you determined your impairment provision and
why you believe it
         to be sufficient given the significant past due amounts. In this
regard, we note your
         accounting policy for trade receivables in critical accounting
policies and estimates on
         page 40 states a provision for impairment of receivables is
established when, among other
         reasons, there is a "delinquency in interest or principal payments."
Please tell us how your
         provision complies with this accounting policy.

         Finally, tell us why you believe it is appropriate to classify such
amounts as current assets
         on your balance sheet.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380
with any
questions.

FirstName LastNameXiangdong Guo
Comapany NameGuangshen Railway Company Limited
                                                                Division of
Corporation Finance
June 26, 2018 Page 2                                            Office of
Transportation and Leisure
FirstName LastName