Mail Stop 4561

      March 13, 2006

VIA U.S. MAIL AND FAX (011 852 2333 8844)

Mr. Bernard Chan
Chief Financial Officer
China World Trade Corporation
The Metropolis Tower, Suite 1217
10 Metropolis Dr.
Hunghom, Hong Kong

      Re:	China World Trade Corporation
      Item 4.01 Form 8-K
      Filed February 21, 2006
      File No. 000-26119

Dear Mr. Chan:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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.
After reviewing this information, we may 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 number
listed
at the end of this letter.

Form 8-K filed February 21, 2006

1. With respect to your disclosure regarding disagreements between
you and your former auditors, please revise Item 4 of Form 8-K to
cover the interim period from the date of the last audited
financial
statements to February 16, 2006 the date of resignation of Moores
Rowland Mazars.  See Item 304(a)(1)(IV) of Regulation S-B.
Include a
letter from the former accountants addressing the revised
disclosures
in the amendment.
2. We note that the audit firm Zhong Yi has not yet completed the
credentialing process and therefore is not yet recognized by the
staff of the SEC.  We understand  that Zhong Yi is currently going
through the credentialing process with the Office of the Chief
Accountant, but until such time as this process is complete and
Zhong
Yi is considered qualified to practice before the Commission, we
may
be unable to accept the audit reports from this firm.  Therefore,
you
should consider whether you wish to engage this firm prior to the
firm completing the credentialing process.  We note that foreign
auditors that wish to practice before the SEC are expected to
demonstrate their knowledge and experience in applying U.S. GAAP,
PCAOB Standards, SEC financial reporting rules and SEC
requirements
prior to inclusion of their audit reports in SEC filings.  The
demonstration of an auditor`s knowledge and experience in advance
of
filing generally applies to all financial statements presented in
SEC
filings, including financial statements provided pursuant to Rule
3-
09 of Regulation S-X. Please note that registration with the PCAOB
does not supersede existing means by which a firm demonstrates its
knowledge and experience in applying US GAAP, PCAOB Standards, SEC
financial reporting rules and SEC independence requirements.  You
may
refer to the International Reporting and Disclosure Issues Outline
available on our website at the following location for additional
information:
http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm
#P3
13_42976.

      As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
respond.
File an amendment under cover of Form 8-K/A and include the ITEM
4.01
designation, including the letter from the former accountant filed
as
an Exhibit 16.  Please note that your former accountants should
make
it clear within the Exhibit 16 letter that it is in reference to
your
amended Form 8-K.  Please understand that we may have additional
comments after reviewing your amendment and response 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.

      Any questions regarding the above should be directed to me
at
(202) 551-3466.



								Sincerely,



								Matthew Maulbeck
								Staff Accountant

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China World Trade Corporation
March 13, 2006



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