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                                January 19, 2023

       Anqiang Chen
       Financial Controller
       Tuniu Corporation
       Tuniu Building No. 32
       Suningdadao, Xuanwu District
       Nanjing, Jiangsu Province 210042
       The People   s Republic of China

                                                        Re: Tuniu Corporation
                                                            Form 20-F for
Fiscal Year Ended December 31, 2021
                                                            Response dated
December 28, 2022
                                                            File No. 001-36430

       Dear Anqiang Chen:

              We have reviewed your December 28, 2022 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 16, 2022 letter.

       Form 20-F for Fiscal Year Ended December 31, 2021

       Item 3. Key Information
       Cash Flows through Our Organization, page 4

   1.                                                   Your discussion of
limitations on cash transfers appears to be limited to the PRC. Given
                                                        that at least one of
the entities in your corporate structure, as per disclosure on page F-9,
                                                        was formed under Hong
Kong law, please revise to also discuss limitations applicable
                                                        to Hong Kong and Macau.
 Anqiang Chen
Tuniu Corporation
January 19, 2023
Page 2


D. Risk Factors, page 11

2.       We have considered your response to prior comment 1 and continue to
believe that
         revised disclosure is necessary. Please revise to discuss any
restrictions, limitations, rules,
         or regulations under Hong Kong and Macau law that are commensurate to
those of the
         PRC.
       You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or
Shannon
Buskirk, Staff Accountant, at 202-551-3717 with any questions.



FirstName LastNameAnqiang Chen                                   Sincerely,
Comapany NameTuniu Corporation
                                                                 Division of
Corporation Finance
January 19, 2023 Page 2                                          Office of
Energy & Transportation
FirstName LastName