SecProbe.io

September 3 , 2013

Via E -mail
Stephane Bello
Executive Vice President & Chief Financial Officer
Thomson Reuters  Corporation
3 Time s Square
New York, New York, 10036

Re: T homson Reuters Corporation
 Form 40-F for Fiscal Year Ended December 31, 201 2
Filed on March 11, 2013
File No. 001 -31349

Dear Mr. Bello :

We have reviewed your response letter dated July 23, 2013 and have the following
comments. In our comments, we ask you to provide us with information so we may better
understand your disclosure.

Please r espond to this letter within 10  business days by confirming that you will revise
your document in future filings  and providing any  reque sted information.   If you do no t believe
our comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have  additional comments.

Form 40 -F for Fiscal Year Ended Dece mber 31, 2012

Appendix E

Critical Accounting Estimates and Judgments, page 72

1. We note your response to prior comment 2 in regard to the Financial &  Risk CGU.  You
state that the discount and tax rates you use are not specific to you, and that using your
actual rates would not be consistent with your methodology that uses the rates of
comparable companies operating in similar industries.  Please expla in to us why you do
not use rates that are specific to you based on your actual experience, and why it is more
meaningful and appropriate to use rates of comparable companies instead.  You also state
that you do not compute an actual tax expense for this C GU as your taxes are managed
on a legal entity rather than on a CGU basis.  In this regard, explain to us why an
allocable portion of your consolidated or applicable legal entity tax expense attributable

Stephane Bello
Thomson Reuters  Corporation
September 3 , 2013
Page 2

 to the contribution of this CGU to either is not con sidered.

2. In determining the perpetual growth rate you use, you disclose that assumptions used are
based on the internal budget and certain projected variables for a period of five years, and
that you consider past experience.  You state in the response th at by its nature, there is no
corresponding actual result for the perpetual growth rate.  Since it appears that five years
of internal budget information is employed in developing the perpetual growth rate and
that past experience is considered, please exp lain to us why the actual growth rate you
experienced in the latest corresponding five year historical period would not be useful
information to investors in assessing the reasonableness of your perpetual growth rate
assumption.    Additionally, please exp lain to us your consideration of and weight given
to the factors you disclosed in regard to this CGU as indicated in our prior comment (i.e.,
(i) restarting its growth, (ii) a 2013 outlook of low single digit revenue growth, (iii)
negative revenue growth i n 2012 from 2011, and (iv) the approximately $100 million in
expected costs to reduce your workforce predominantly within this CGU) in determining
your perpetual growth rate assumption.

3. Please explain to us in more detail why you believe that a comparison  of the actual free
cash flow rate in a current period with the long -term compound annual growth rate
assumption would not be helpful to an investor.  From your response it appears the
assumed free cash flow rate is for a five year period and is based on i nternal information.
In this regard, please explain to us why the actual free cash flow rate you experienced in
the latest corresponding five year historical period would not be useful information to
investors in assessing the reasonableness of your free cash flow rate assumption.

You may contact Aamira Chaudhry at 202 -551-3389 or Doug Jones at 202 -551-3309 if
you have questions regarding comments on the financial statements and related matters.  Please
contact me at 202 -551-3380 with any other question s.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief