The purpose of the present invention is to provide a tube assembly for a tubular heat exchanger and a tubular heat exchanger comprising the same, the tube assembly for a tubular heat exchanger being capable of enhancing efficiency in heat exchange between a heat medium and a combustion gas and also preventing high-temperature oxidation and the burn-out of a turbulator caused by the combustion heat of the combustion gas and preventing the deformation or damage of a tube which may occur in an environment with a high water pressure, thereby improving the durability thereof. The tube assembly for a tubular heat exchanger of the present invention, for achieving the purpose, comprises: a tube which is formed in a flat shape and enables a combustion gas generated in a combustion chamber to flow along the inside thereof and exchange heat with a heat medium which flows outside thereof; and a turbulator which is coupled to the inside of the tube and induces the generation of turbulence in the flow of the combustion gas.