SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE      Mail Stop 3030

         A u g u s t  2 8 ,  2 0 0 9
   Mr. Hoh Weng Ming Chief Financial Officer China Yuchai International Limited 16 Raffles Quay #26-00 Hong Leong Building Singapore 048581
Re: China Yuchai International Limited
 Form 20-F for Fiscal Year Ended December 31, 2008
Filed April 8, 2009
          File No. 001-13522

Dear Mr. Ming:
We have reviewed your filings and have the following comments.  Where
indicated, we think you should revise your future  filings 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 de tailed as necessary in your explanation.  In
some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  Af ter reviewing this information, we may or
may not raise additional comments.
Please understand that the purpose of our re view 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 numbers listed at the end of this letter.

Mr. Hoh Weng Ming
China Yuchai International Limited
August 28, 2009 Page 2    Form 20-F for the Fiscal Year Ended December 31, 2008

 1. We note that your shares of Yuchai are your  primary asset.  We also note that
your plans for expansion and diversificati on, as described on page 44, appear to
emphasize the acquisition of investment secu rities (for instance, the securities of
TCL and HLGE.)  Please provide your analysis as to whether you should be
considered an “investment company” within the meaning of  Section 3 of the
Investment Company Act of 1940.
 Item 6.  Directors, Senior Ma nagement and Employees, page 63

 2. In future filings, please provide inform ation regarding share ownership held by
your directors and members of your admini strative, supervisory or management
bodies.  Refer to Item 6.E. of Form 20-F.

Item 8.  Financial Information
Consolidated Statements of Shareholders’ Equity and Comprehensive Income/(Loss),
page F-8
 3. We see that in 2008 you reported unrealized losses totaling Rmb80 million
identified as related to investments held by an affiliate.  Please explain to us the
source of the unrealized loss, the nature of the investments and the affiliate to which it relates.  Please tell us where th e notes to financial statements provide
disclosure about these investments and the specific accounting applied.
 4. As a related matter, please reconcile for us the change in the unrealized gains in your available for sale securities betw een 2007 and 2008 as disclosed in Note 17
to the amounts presented in the statement of  stockholders’ equity.   In that regard,
we see that Note 17 indicates that unreal ized gains on available for sale securities
were Rmb101 million as of December 31, 2007 (Form 20-F as of December 31,
2007, page F-33) and Rmb51 as of December 31, 2008.
 Note 3.  Summary of Significant Accoun ting Policies and Practices, page F-13

(c) Trade Accounts Receivab le, loans receivable and bills receivable, net
 5. We see that some bills receivable are in cluded in your balance sheet while others
are apparently de-recogni zed upon sales to banks.  In future filings, please
disclose the criteria you apply in determ ining the appropriate accounting for bills
receivable sold to banks.  That is, cl arify the criteria you ev aluate in assessing
whether de-recognition is appropriate in GAAP.  In future filings, please also
clarify the difference between a trade account receivable and a bill receivable.

Mr. Hoh Weng Ming
China Yuchai International Limited
August 28, 2009 Page 3    (k)  Revenue recognition

 6. It appears that you have se rvice centers and that you pr ovide other services to
customers.  Unless insignificant, in future filings please also provide an accounting policy disclosure for service revenues.
 (q) Impairment of long-live d assets, other than goodwill

 7. In future filings please describe the facts and circumstances leading to the
impairment charge for the hotel and offi ce building in 2008.  In that regard, please
describe the business and operational factor s leading you to conclude that future
cash flows would not be as originally anticipated.
 (r) Fair Value Measurements, page F-17

 8. In the last sentence of the next to last paragraph you indicate that “financial
investments” were valued by a professional a ppraiser.  Please tell us and in future
filings disclose which instruments you are re ferring to as financial investments.
Also tell us the extent to which you relie d on the opinion of the outside expert in
valuing these instruments.  Please note that if you di sclose that you relied on an
outside appraiser in these va luing financial instruments, you may need to identify
the expert in future filings and include their consent in any registration statement incorporating the Form 20- F.  Please also refer to Question 141.02 of the
Compliance and Disclosure Interpre tations on Securities Act Sections.
 Note 17.  Investments, F-28

(e) Other investments as of December 31, 2007 and 2008 not described above…, page F-
33
 9. We see the general disclosure about how you determine the fair value of level 3
investments under the caption “Securities.”  Tell us and in future filings please disclose how you actually determined the fa ir value of the level 3 investments in
HLGE.  In that regard, please provide cl ear disclosure of the model or models
applied and a description of the key a ssumptions applied in your modeling.
 10. In that regard your disclosure indicates that HLGE has an ex cess of liabilities over
assets.  We also see that through a subs idiary you refinanced bonds receivable
from HLGE in 2009, prior to their matur ity.  Please tell us why you believe the
carrying amount of the bonds is recoverable at December 31, 2008.

Mr. Hoh Weng Ming
China Yuchai International Limited
August 28, 2009 Page 4    11. We refer to the table disclosing the initi al value, gross unrealized holding gains
and period-end fair value of investment s ecurities appearing on page F-33.  In
future filings please provide the disclosure of gross unrealized gains, gross unrealized losses (when applic able) and fair value of available for sale securities
as of each balance sheet date included in your filing.  Refer to FASB ASC 320-
10-50-2.

*****

 As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Pl ease furnish a cover letter that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
   We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Mr. Hoh Weng Ming
China Yuchai International Limited  August 28, 2009 Page 5     You may contact Jong Hwang at (202) 551-3327 or me at (202) 551-3605 if you
have questions regarding comments on the fi nancial statements and related matters.
Please contact Gabriel Eckstein at (202) 551-3286 or Daniel Morris, Special Counsel, at (202) 551-3314 with any other questions.
Sincerely,

Gary Todd Senior Review Accountant