The international and AI-driven second curve.

Trip.com Group delivered FY2025 net revenue of ¥62.4 billion (about US$8.93B), up 17% YoY; attributable net income reached ¥33.3 billion (including a one-time investment gain of ¥19.9B), with adjusted EBITDA margin of 30%. Cross-border travel and the AI recommendation features inside the Trip.com international brand have become structural growth pillars. This report is built from three primary SEC filings — the FY2024 20-F, the 2025 Q3 6-K, and the 2025 Q4 / FY2025 6-K — with figures denominated in renminbi (¥); US dollar equivalents shown in parentheses use the period-end FX rate.

Quick numbers

§01 · Key Metrics — the year at a glance

2025 was Trip.com’s first fully normalized post-pandemic fiscal year. Outbound air ticketing and accommodation bookings recovered to about 140% of the same period in 2019, and the Trip.com international brand continued to expand rapidly across Asia-Pacific and Europe. The doubling of headline net income was driven by an investment fair-value gain (¥19.9B one-off, primarily from equity holdings); excluding non-recurring items, non-GAAP attributable net income reached ¥31.8B (US$4.6B), up 77% YoY — core operating leverage continues to deliver.

— Data from the Q4/FY2025 6-K released 2026-02-25

§02 · Business — five segments, one ecosystem

§03 · P&L — core earnings vs one-time gains

Income statement (quarterly + full year)

RMB millions · per SEC disclosure.

Q3 net income of ¥19.9B includes the Tongcheng investment fair-value gain ¥19.9B (pre-tax ¥16.7B + tax effect).

Core observations · earnings quality takeaways

1. Core operating income +11%. Stripping the investment fair-value gain, operating income was ¥15.77B (+11%); non-GAAP attributable net income ¥31.8B (+77%).
2. Accommodation is the profit core. Accommodation revenue ¥26.1B (+21%) outpaces total +17%; take rate stable at ~8–10% (not separately disclosed).
3. S&M ratio rises to 24%. FY25 sales & marketing ¥14.9B (+25%) was directed mainly at international brand promotion; Q4 hit 29% — characteristic of a growth-stage investment phase.
4. SBC steps up materially. FY25 stock-based compensation totaled ¥2.27B (FY24: ¥2.04B); 3.6% of net revenue, on the lower end versus peers.
5. Effective tax rate jumps. FY25 income tax of ¥5.8B (FY24: ¥2.6B), primarily driven by deferred tax triggered by Q3’s Tongcheng disposition.

§04 · Balance — cash-rich, light-leveraged

Balance sheet comparison

2024-12-31 vs 2025-12-31 · RMB millions.

Basis: Trip.com reports in RMB; USD figures translated at the period-end FX rate of 7.0018. Currency: RMB primarily, USD as management-disclosed equivalents.

ADS structure · capital

1 ADS = 1 ordinary share.

The Trip.com ADS structure mirrors the single-class ordinary structure of A-share/H-share peers — each ADS corresponds to one ordinary share, with no dual-voting arrangements. Period-end diluted shares 698.4M, basic 657.8M, dilution factor 6%, a healthy level.

§05 · Cash Flow — cash, not accounting

Key cash flow takeaways

1. OCF ~¥18.0B (estimated). Basis: anchored on adjusted EBITDA ¥18.9B less working capital and tax; management does not split quarterly OCF/FCF.
2. Low Capex ratio, asset-light. FY25 PP&E + software balance was ¥5.4B (vs FY24 ¥5.0B), a net add of ¥0.4B — under 1% of revenue.
3. SBC ratio modest. FY25 SBC ¥2.27B (+11%), 3.6% of net revenue, well below US internet peers (10–20%).
4. Long-term debt down ¥8.7B. Long-term debt fell from FY24’s ¥20.1B to ¥11.4B (-43%), reflecting partial conversion or redemption of convertible notes.
5. Buyback authorization pending. The market expects a new buyback program to start in Q1 2026; this 6-K does not disclose the amount.

§06 · Leadership — who’s running this

Executive officers and board

The following are the named executives disclosed in the FY2024 20-F annual report. On 2026-02-25, Trip.com announced a board change: co-founders Min Fan and Qi Ji resigned as directors, and May Yihong Wu and Iris Yang Xiao were appointed as new independent directors; Gabriel Li joined the compensation committee. The four-person C-suite — Liang, Sun, Wang, and Xiong — remained stable.

Governance & event timeline

FY2024 20-F + Q3/Q4 2025 6-K disclosures.

1. 2025-Q3. Q3 6-K disclosure: Jane Sun emphasizes “cross-border travel” and AI upgrades end-to-end.
2. 2025-Q4. Q4 6-K: James Liang positions “inbound travel” investment commitments as the core narrative.
3. 2026-01. The State Administration for Market Regulation (SAMR) opens an antitrust investigation under the Anti-Monopoly Law.
4. 2026-02-25. Min Fan and Qi Ji resign as directors; two new female independent directors May Wu & Iris Xiao join.

Board of Directors (effective 2026-02-25)

8 directors · 5 independent · improved diversity.

Trip.com is incorporated in the Cayman Islands; Chinese operations run through a VIE structure. Of the 8 board seats, 5 are independent (including the 2 new female directors) — a meaningful improvement in independence over time. The founder cohort completed its first systemic “step-back” by year-end 2025.

§07 · Risk — what could derail this

1. SAMR antitrust probe · ongoing. In January 2026 the State Administration for Market Regulation opened an antitrust investigation under the Anti-Monopoly Law; the company disclosed in the Q4 6-K that it is cooperating. The outcome is unknown — possible angles include platform “either-or” exclusivity, exclusive agreements, and historical “big data discrimination” allegations. This is the largest single point of uncertainty today; near-term it may pressure valuation, and long-term it may force business-model adjustments.
2. China-ADR VIE structure and HFCAA. Trip.com is Cayman-incorporated, dual-listed in the US/HK, and controls onshore operating entities through VIE agreements; subject to the Holding Foreign Companies Accountable Act (HFCAA) and SEC audit oversight. PCAOB completed its inspection in 2024, but geopolitical tail risk persists.
3. Cross-border travel policy and macro. The FY25 narrative leans heavily on “cross-border recovery” — China outbound +40% vs 2019. A macro slowdown, a sharp RMB depreciation, or tightening of China-US/Japan/Korea visa policies would directly hit international growth.
4. Competitive pressure · Meituan / Douyin / Booking. Domestically Meituan Hotels and Douyin local services are eating mid- and low-end share; internationally Booking Holdings, Agoda, and Expedia are pressing the Trip.com international brand with mature-market direct-response budgets. FY25 sales-cost ratio rose from 22% to 24%, reflecting “must keep investing.”
5. Investment fair-value volatility. More than half of FY25 GAAP net income came from fair-value gains on equity holdings such as Tongcheng (¥19.9B). A market downturn could reverse quickly — non-GAAP attributable net income of ¥31.8B excludes this item, but investor sentiment will still react sharply to GAAP numbers.

Bottom line · Cash-rich, internationalization in delivery, regulation the biggest variable.

In 2025 Trip.com completed the narrative shift from “post-pandemic recovery” to “international growth.” Pricing for the next 1–2 years hinges on:

• The path and outcome of the SAMR antitrust probe
• Whether the Trip.com international brand can maintain 50%+ growth
• Whether accommodation take rate is further eroded by Meituan/Douyin
• Capital allocation of the ¥105.8B liquidity (buyback / dividend / M&A)
• Whether AI recommendation translates into structural take-rate uplift

“Net cash ¥75B · international second curve · deep brand-portfolio moat” — the three together provide a downside floor.

§08 · Valuation — valuation in context

TCOM current valuation

Data as of 2026-04-17 · close · per ADR.

Peer benchmark

Global OTAs · TTM · latest.

On current valuation, TCOM’s P/E (TTM) of just 8× sits well below BKNG (19×), EXPE (23×), and ABNB (31×) — reflecting the textbook “China-ADR discount” (VIE structure, HFCAA tail risk, RMB-denominated narrative) rather than core operating-quality differences; stripping out the FY25 one-time fair-value gain, TCOM’s “real” P/E is about 12× — the discount narrows but persists. On P/S, TCOM and ABNB are both in the 6× cohort, above BKNG/EXPE — the market is already paying some premium for accommodation (42% of revenue, +21%) and the international second curve, not pricing TCOM purely as a “China traffic stock.” EV/EBITDA of ~10× sits between EXPE (13×) and BKNG (17×), closer to mature OTAs than to high-growth platforms; FCF Yield of 5.8% is on par with BKNG/ABNB, signaling cash-generation acceptance. The largest near-term overhang remains the SAMR antitrust probe opened in January 2026 — a moderate path (fines + business normalization) leaves clear room for the discount to close; structural remedies, on the other hand, would compress the multiple further.