EXHIBIT 8.2

                                                                    May 11, 2007

Yingli Green Energy Holding Company Limited
No. 3055 Middle Fuxing Road
Baoding 071051
People's Republic of China

Ladies and Gentlemen:

          We have acted as United States counsel to Yingli Green Energy Holding
Company Limited (the "Company"), in connection with the Registration Statement
on Form F-1 (File No. 333-_________), including the prospectus contained therein
(together, the "Registration Statement"), filed by the Company with the U.S.
Securities and Exchange Commission (the "Commission") under the U.S. Securities
Act of 1933, as amended (the "Securities Act"), relating to the registration of
shares of the Company's Common Stock, par value US$0.01 per share, which will be
represented by American Depositary Shares evidenced by American Depositary
Receipts.

          We have examined the Registration Statement. In addition, we have
examined, and have relied as to matters of fact upon, originals, or duplicates
or certified or conformed copies, of such corporate records, agreements,
documents and other instruments and such certificates or comparable documents of
public officials and of officers and representatives of the Company, and have
made such other and further investigations as we have deemed necessary or
appropriate as a basis for the opinion hereinafter set forth. In such
examination, we have assumed the accuracy of the factual matters described in
the Registration Statement and that the Registration Statement and other
documents will be executed by the parties in the forms provided to and reviewed
by us.



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                                                                    May 11, 2007

          Based upon the foregoing, and subject to the qualifications,
assumptions and limitations stated herein and in the Registration Statement, we
hereby confirm that the statements set forth under the caption "Taxation -
United States Federal Income Taxation," to the extent they state matters of law
or legal conclusions, constitute the opinion of Simpson Thacher & Bartlett LLP.

          We do not express any opinion herein concerning any law other than the
United States federal income tax law.

          We hereby consent to the filing of this opinion with the U.S.
Securities and Exchange Commission as an exhibit to the Registration Statement
and to the reference to our firm under the headings "Legal Matters" and
"Taxation--United States Federal Income Taxation" in the Registration Statement.

                                        Very truly yours,

                                        /s/ Simpson Thacher & Bartlett LLP


                                        SIMPSON THACHER & BARTLETT LLP