SecProbe.io

August 1, 2005

Via US Mail and Facsimile

Mr. Zha Zianping
Chief Financial Officer
Brilliance China Automotive Holdings Limited
Suites 1602-05
Chater House
8 Connaught Road Central
Hong Kong

Re: Brilliance China Automotive Holdings Limited
 Form 20-F for the year ended December 31, 2004
 Commission File Number:  001-11412

Dear Mr. Zianping:

We have reviewed the above referenced filing and have the following comments.  We have
limited our review to the financial statements and related disclosures included within these
documents.  Understand that the purpose of our  review process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.

Where expanded or revised disclosure is reque sted, you may comply with these comments in
future filings.  If you disagree, we will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.  In so me of our comments, we may ask you to provide
us with supplemental information so we may be tter understand your disclosure.  Please be as
detailed as necessary in your explanation.

We look forward to working with you in thes e respects and welcome any questions you may
have about any aspects of our review.

* * * * * * * * * * * * * * * * * * * * * * *
Item 5. Operating and Financial Review and Prospects

Liquidity and Capital Resources

Table of Contractual Obligations, page 41
1. We note that you have included only uncondition al purchase obligations  and operating lease
payments in your table of contractual oblig ations, but you issued convertible bonds in

Mr. Zha Zianping
Brilliance China Automotive Holdings Limited
August 1, 2005
Page 2

November 2003 that have not yet been redeeme d.  Please revise your table of contractual
obligations to include the pr incipal amount of the convertib le bonds issued in November
2003 as well as the total interest to be accr ued over the remaining term.  Your tabular
disclosure should be accompanied by a footnote explanation of the methodology used in the
calculation of total interest.  See Se ction IV.A of FR-72 for guidance.

2. It appears you have other debt obligations, such as bank notes  payable and notes payable to
affiliated companies, that should be included (along with related interest) in your table of contractual obligations.  Pleas e revise, as appropriate.

Note 3 – Summary of Significant Accounting Policies

(d) Inventories, page F-14
3. We note from your policy discussion here and elsewhere in your filing that you provide and
allowance for excess and obsolete inventory.  Supplementally explain to us and expand your
disclosure in future filings to include how you identify excess or obsolete inventory.

4. As a related matter, we note from your statem ent of cash flows presented on page F-7 that it
appears you have sold a material amount of pr eviously reserved inventory.  Supplementally
explain the facts and circumstances surrounding the initial recognition of a reserve on this
inventory as well those surrounding the sale of such inventory during 2004.

Note 11 – Property, Plant, and Equipment, page F-29

5. We note that you have recognized an impairme nt of RMB 10 million on property, plant, and
equipment.  In this regard, please revise your disclosure to include th e disclosures required
by paragraph 26 of SFAS 144.

Note 12 - Intangible Assets, page F-30

6. We note that from your disclosure on page F-14 th at purchased intangible  assets with finite
lives are amortized over a period of 7 years.  We also note from your disclosure in Note 12
on page F-31 that two major in tangible asset classes compri se your balance: sedan design
rights and component and parts technology rights.  Please revise  your disclosure to present
the items required by paragraph 44 of SFAS 142 for each of these major intangible asset
classes.

7. As a related matter, supplementally explain to us  how the impairment of the intangible assets
related to the Zhonghua sedan has affected your assessment of their estimated economic
lives.  We may have further comment on your response.

* * * * * * * * * * * * * * * * * * * * * * *

Mr. Zha Zianping
Brilliance China Automotive Holdings Limited
August 1, 2005
Page 3

We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure in the
filings reviewed by the staff to be certain that  they have provided a ll information investors
require.  Since the company and its management  are in possession of a ll 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 disclo sure in the filings;
‚ staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose th e 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 federa l securities laws of  the United States.

In addition, please be advised th at the Division of Enforcement has access to all information you
provide to the staff of the Division of Corporat ion Finance in our review  of your filing or in
response to our comments on your filing.

Please file your response to our comments via EDGAR within ten business days from the date of
this letter.  Please understand that we may have additional comments after reviewing your
response.  You may contact Amy Geddes at  202-551-3304 or me at 202-551-3211 if you have
questions or any concerns as I supervised the review of your filing.

        S i n c e r e l y ,

        David R. Humphrey
        B r a n c h  C h i e f