February 28, 2019

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 reviewed your January 9, 2019, response to our comment letter
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. Unless we note otherwise, our references to prior comments are to
comments in our
December 21, 2018, letter.

Form 10-Q for the Thirteen Weeks Ended September 30, 2018

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

1.    We have read your response to comment 1 from our letter dated December
21, 2018.
      With reference to ASC 606-10-32-25 through 27 and ASC 606-10-25-19,
please address
      the following:
        Explain how you determine the nature and dollar amount of the
promotional offers
          you offer to your independent sales force, including whether specific
promotional
          offers relate to specific goals or targets;
        For promotional offers related to fulfilling specific goals for adding
sales force
          members, party attendance and other "business building endeavors",
explain in greater
          detail how the benefit(s) received are distinct within the context of
the contract from
 Michael Poteshman
TUPPERWARE BRANDS CORP
February 28, 2019
Page 2
             your sale of goods to your independent sales force. In this
regard, it is unclear whether
             there are benefits for these services distinct from the additional
sales made by the same
             sales team members. For example, it appears the sales force member
who increased
             party attendance would make the sale to the party attendees, and
Tupperware does not
             control the promotional services. Also, explain how you determine
the fair value of the
             distinct service; and
             Define "targeted organization sales". Clarify whether you offer
cash or product
             awards for the attainment of targeted organizational sales.
Explain how you
             determined that the benefit received by you is distinct within the
context of the
             contract from your sale of goods.
       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 Terence O'Brien,
Accounting
Branch Chief, at (202) 551-3355 if you have questions regarding comments on the
financial
statements and related matters.



                                                               Sincerely,
FirstName LastNameMichael Poteshman
                                                               Division of
Corporation Finance
Comapany NameTUPPERWARE BRANDS CORP
                                                               Office of
Manufacturing and
February 28, 2019 Page 2                                       Construction
FirstName LastName