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                             June 29, 2022

       Xinpeng Luo
       Chief Accountant
       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
Fiscal Year Ended December 31, 2020
                                                            Form 20-F for
Fiscal Year Ended December 31, 2021
                                                            Response dated
April 26, 2022
                                                            File No. 001-14362

       Dear Mr. Luo:

              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, 2021

       Item 3. Key Information
       D. Risk Factors
       Risks Relating to Conducting Business in China, page 4

   1.                                                   We have considered the
revision you made in response to prior comment 7. Please further
                                                        revise your risk factor
presentation to place the subsections titled    Risks Associated with
                                                        Chinese Accounting
Firms    and    Risks Associated with Technology and Cybersecurity"
                                                        directly after the
subsection titled    Risks Relating to Conducting Business in China.
 Xinpeng Luo
FirstName
GuangshenLastNameXinpeng
           Railway Company Luo
                           Limited
Comapany
June       NameGuangshen Railway Company Limited
     29, 2022
June 29,
Page 2 2022 Page 2
FirstName LastName
Government control of currency conversion may adversely affect our operations
and financial
results., page 6

2.       We note your response to prior comment 13. Please further revise your
disclosure to
         quantify any cash flows and transfers of other assets by type that
have occurred between
         you and your subsidiaries, including the direction of transfer.
Quantify any dividends or
         distributions that a subsidiary has made to you and which entity made
such transfer, and
         their tax consequences. Similarly quantify dividends or distributions
made to U.S.
         investors, the source, and their tax consequences. Your risk factor
disclosure should make
         clear whether transfers, dividends, or distributions have been made to
date. Please ensure
         that your revised disclosure addresses each element of prior comment
13. For example,
         while your response states that you have distributed dividends for 24
consecutive years
         from 1996 to 2019 and have not experienced any regulatory obstacles in
terms of cross-
         border cash transfer and foreign currency exchanges, your revised
disclosure should
         include a description of any restrictions and limitations on your
ability to distribute
         earnings, including with regard to your subsidiaries and U.S.
investors.
We are subject to extensive and evolving legal system in the PRC ..., page 9

3.       We note the revised disclosure provided in response to prior comment
12. Please revise
         your disclosure further to address each permission or approval that
you or your
         subsidiaries are required to obtain from Chinese authorities to
operate your business. In
         addition, state affirmatively whether you have received all requisite
permissions or
         approvals from any governmental agency that is required to approve
your operations and
         whether any permissions or approvals have been denied.
Extensive government regulation of the railway transportation industry ...,
page 11

4.       We note the disclosure added in response to prior comment 1 identifies
the railroad
         transportation services and railway infrastructure and transportation
generally as    key
         parts of China   s comprehensive transportation system.    However, it
appears that
         expanded disclosure should be provided regarding the designation of
the railroad sector as
         a national security interest more generally (i.e., the scenario where
foreign investment is
         deemed to impact or potentially impact the national security of The
People   s Republic of
         China) and the effect that this type of designation would have on your
operations, ability
         to transfer capital out of China or enter into business transactions
with non-Chinese
         parties, and the value of your ADSs.
Risks Associated with Technology and Cybersecurity
Substantial uncertainties exist with respect to the interpretation and
implementation of ..., page
18

5.       The revised disclosure provided in response to prior comment 3 states
that you have not
         been subject to any investigations relating to cybersecurity made by
the Cyberspace
         Administration of China (CAC), but there is no assurance that you can
fully or timely
 Xinpeng Luo
Guangshen Railway Company Limited
June 29, 2022
Page 3
         comply with laws and regulations regarding privacy, data security,
cybersecurity, and data
         protection. Revise your disclosure to clarify whether you believe you
are compliant with
         these laws and regulations.
Risks Associated with Chinese Accounting Firms
The PCAOB is currently unable to inspect our auditor in relation to their audit
work ..., page 19

6.       We note your disclosure stating that you expect to be identified as a
  Commission
         Identified Issuer    shortly after the filing of this annual report.
Please revise to state that
         you have been included in the list of issuers identified under the
HFCAA. In addition,
         within your filing, provide more prominent disclosure regarding your
identification as an
         issuer on this list.
Item 4 - Information on the Company
C. Organizational Structure, page 34

7.       We note the diagram added to page 34 in response to prior comment 14.
Please further
         revise to reflect the shareholding structure of your company as
reflected on page 61,
         which includes the Public shareholders of H shares, China Railway
Guangzhou Group
         Co., Ltd. (   GRGC   ), a state-owned enterprise, and the Other public
shareholders of A
         shares.
       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 Jennifer O'Brien, Staff Accountant, at 202-551-3721 or
Ethan
Horowitz, Branch Chief, at 202-551-3311 with any questions.



FirstName LastNameXinpeng Luo                                    Sincerely,
Comapany NameGuangshen Railway Company Limited
                                                                 Division of
Corporation Finance
June 29, 2022 Page 3                                             Office of
Energy & Transportation
FirstName LastName