December 21, 2018

Michael Poteshman
Chief Financial Officer
TUPPERWARE BRANDS CORP
14901 South Orange Blossom Trail
Orlando, Florida

       Re: TUPPERWARE BRANDS CORP
           Form 10-Q For The Thirteen Weeks Ended September 30, 2018
           Filed November 2, 2018
           File No. 001-11657

Dear Mr. Poteshman:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-Q For The Thirteen Weeks Ended September 30, 2018

Note 1. Summery of Significant Accounting Policies - Revenue Recognition and
Note 3.
Promotional Cost, page 7

1.    We note that you frequently make promotional offers to members of your
independent
      sales force (i.e. your customers) to encourage them to fulfill specific
goals or targets for
      sales levels, party attendance, addition of new sales force members or
other business-
      critical functions. Please tell us how you considered the guidance in ASC
606-10-32-25
      through 27 in your determination that these costs should be reflected as
promotional costs
      rather than as a reduction to revenue. Address this comment as it relates
to the nature of
      each type of consideration (e.g., cash, price reductions, product awards,
special prizes or
      trips) and identify the distinct good or service your customer transfers
to you.


2.    We note that when revenue is recorded, estimates of returns are made and
recorded as a
      reduction of revenue. If material, please tell us, and revise to disclose
how you account for
 Michael Poteshman
TUPPERWARE BRANDS CORP
December 21, 2018
Page 2
         returns, if different from other variable consideration. For example,
please tell us and
         revise to disclose if you record a refund liability and asset for the
right to recover goods
         from your independent sales force at the time of sale. See guidance in
ASC 606-10-32-10
         and 606-10-55-22 through 55-29.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Tracey McKoy, Staff Accountant, at (202) 551-3772 or, in
her absence
Jeanne Baker, Assistant Chief Accountant, at (202)551-3691 or, in her absence
Terence O'Brien,
Accounting Branch Chief, at (202) 551-3355 with any questions.



                                                               Sincerely,
FirstName LastNameMichael Poteshman
                                                               Division of
Corporation Finance
Comapany NameTUPPERWARE BRANDS CORP
                                                               Office of
Manufacturing and
December 21, 2018 Page 2                                       Construction
FirstName LastName