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    CHINA
WORLD TRADE CORPORATION

    5/F,
Guangdong Finance Building

    88
Connaught Road West

    Hong
Kong

    SAR of
the People’s Republic of China

    July 29,
2008

    U.S.
Securities and Exchange Commission

    Division
of Corporation Finance

    100 F
Street, N.E.

    Mail Stop
4561

    Washington,
D. C. 20549-7010

    ATTN:       Christine
Davis

    Assistant Chief Accountant

    Re: China
World Trade Corporation

    Form
10-KSB for Fiscal Year Ended December 31, 2007

    File No. 000-26119

    Ladies
and Gentlemen:

    Thank you
for your comment letter dated July 21, 2008 (the “Comment Letter”), with respect
to the above-captioned Form 10-KSB for fiscal year ended December 31,
2007.  Our amended Form 10-KSB/A of China World Trade Corporation, a
Nevada corporation (the “Company”) incorporates our responses to your comments,
and this letter sets forth each of your comments with our responses
below.

    For your
information, we have filed our amended Form 10-KSB/A annual report for the
fiscal year ended December 31, 2007 on the EDGAR system, and have also provided
clean and marked copies to the Staff by overnight courier.

    Form 10-KSB for Fiscal Year
Ended December 31, 2007

    Item 8A. Controls and
Procedures

              1.

              It
      does not appear that your management has performed its assessment of
      internal control over financial reporting as of December 31,
      2007.  Since you were required to file or filed an annual report
      for the prior fiscal year, it appears that you are required to report on
      your management’s assessment of internal control over financial
      reporting.

    If your
management has not yet performed its assessment, we ask that you complete your
evaluation and amend your filing within 30 calendar days to provide the required
management’s report on internal control over financial reporting.

    In
performing your evaluation, you may find the following documents
helpful:

              ·

              the
      Commission’s release Amendments to Rules Regarding
      Management’s Report on Internal Control Over Financial Reporting
      (Securities Act Release 8809/Financial Reporting Release 76). You can find
      this release at: http://ww.sec.gov/rules/final/2007/33-8809.pdf;

              ·

              the
      Commission’s release Commission Guidance Regarding
      Management’s Report on Internal Control Over Financial Reporting Under
      Section 13(a) or 15(d) of the Securities Exchange Act of 1934
      (Securities Act Release 8810/Financial Reporting Release 77). You can find
      this release at: http://sec.gov/rules/interp/2007/33-8810.pdf;
      and

              ·

              the
      “Sarbanes-Oxley Section 404 – A Guide for Small Business” brochure at:
      (http://www.sec.gov/info/smallbus/404guide.shtml).

              Response 1: Management
      did perform its assessment and complete its report of internal control
      over financial reporting as of December 31, 2007. However, the disclosure
      required under Item 308(a) was inadvertently omitted from our Form 10-KSB
      for the fiscal year ended December 31, 2007, which was filed with the
      Commission on March 31, 2008. In Amendment No. 1 to our Form 10-KSB/A, we
      have added Item 8AT, which provides the necessary disclosure about
      management’s evaluation of internal control over financial
      reporting.

              2.

              Please
      consider whether management’s failure to perform or complete its report on
      internal control over financial reporting impacts its conclusions
      regarding the effectiveness of your disclosure controls and procedures as
      of December 31, 2007 and revise your disclosure as
      appropriate.

              Response 2: Since
      management did perform and complete its report on internal control over
      financial reporting, there was no impact on our conclusions regarding the
      effectiveness of our disclosure controls and procedures as of December 31,
      2007.

              3.

              We
      note your disclosure that your chief executive and chief financial
      officers concluded your disclosure controls and procedures were effective
      at a reasonable assurance level to ensure that “material information
      relating to the Company is made known to management, including the CEO and
      CFO, particularly during the period when [y]our periodic reports are being
      prepared…” This effectiveness conclusion is stated in terms that is more
      limited in scope than the definition of “disclosure controls and
      procedures” in Exchange Act Rule 13a-15(e).  The rule requires,
      among other matters, that the disclosure controls and procedures be
      designed “to ensure that information required to be disclosed by the
      issuer in the reports that it files or submits under the Act… is recorded,
      processed, summarized and reported, within the time periods specified in
      the Commission’s rules and forms” and to ensure that “information required
      to be disclosed by an issuer… is accumulated and communicated to the
      issuer’s management… as appropriate to allow timely decisions regarding
      required disclosure.”  Please revise your disclosure to indicate
      whether the effectiveness conclusions of the CEO and CFO were made with
      respect to the company’s disclosure controls and procedures as defined in
      Exchange Act Rule 13a-15(e).

              Response 3: We have
      revised our disclosure to comply with Exchange Act Rule 13a-15(e), as
      requested.

              4.

              You
      also disclose that “there has been no change in [y]our Internal Controls
      that occurred during [y]our most recent fiscal quarter or fiscal year that
      has materially affected, or is reasonably likely to affect, [y]our
      Internal Controls.”  Please revise to disclose whether or not
      there have been changes in your internal controls over financial
      reporting during your last fiscal quarter that has materially
      affected, or is reasonably likely to materially affect, your internal
      control over financial reporting.  See Item 308(c) of Regulation
      S-B.

              Response 4: Disclosure
      regarding changes in internal control over financial reporting during our
      last fiscal quarter is included in Item 8AT of our amended 10-KSB/A
      filing, in which we report that there have been no
  changes.

    Exhibit 31.1 and
31.2

              5.

              We
      note that you filed your Principal Executive Officer and Principal
      Financial Officer certifications under Item 601(b)(31) of Regulation
      S-B.  Such certifications should reflect the exact wording in
      Item 601(b)(31).  Please revise these certifications as
      follows:

              ·

              Remove
      the certifying individual’s title from the introductory sentence to the
      certification;

              ·

              Replace
      the phrase “annual report” with the word “report” in paragraphs 2 and 3;
      and

              ·

              Include
      the introductory language of paragraph 4 and the language of paragraph
      4(b) of Item 601(b)(31) of Regulation
S-B.

              Response 5: The
      requested changes to the certifications of our Principal Executive Officer
      and Principal Officer have been made so that Exhibits 31.1 and 31.2 now
      reflect the exact wording set forth in Item 601(b)31 of Regulation
      S-B.

    We
acknowledge that:

              ·

              The
      company is responsible for the adequacy and accuracy of the disclosure in
      the filings;

              ·

              Staff
      comments or changes to disclosure in response to staff comments do not
      foreclose the Commission from taking any action with respect to the
      filings; 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.

    Please
let us know if you have any further questions.  We would appreciate if
you would advise us at your earliest convenience if any further changes may be
necessary to our filings.

    Sincerely,

    /s/
Cheung Chi Ho

    Cheung
Chi Ho

    Chief
Executive Officer

    cc:  Harold
H. Martin, Esq.

    Enclosures

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