Trip.com Group (TCOM)
Agencias de viaje en línea
A single-stop travel platform with four brands (Ctrip, Qunar, Trip.com and Skyscanner) trading at 8× its operating income excluding the SAMR fine, with net cash on the balance sheet; the market is discounting the antitrust penalty and the Q2 2026 slowdown, and at $41 the estimated five-year return is +25% (Very undervalued).
Moat Compounder estimates the intrinsic value of Trip.com Group (TCOM) at $123 per share on a five-year horizon. With the stock at $40.63 at 2026-09-23 close, the expected total return is 24.7% per year: very undervalued. The analysis draws on 20-F FY2025 and 6-K 2Q2026 and first half (ex-99.1, accession number 0001193125-26-392473). Analysis dated 2026-09-16.
- Price
- $40.63
- Intrinsic value (5y, base)
- $123
- Total annual return (5y)
- 24.7%
- Status (nominal)
- Very undervalued
- Margin of safety
- +59%
The essentials
- An agency platform with a network effect and four brands; revenue of RMB65.7 billion in the twelve months to Jun 30, 2026 and a 24.0% operating margin excluding the SAMR fine.
- Trades at 8× operating income excluding the sanction, with net cash of RMB47.9 billion (already net of the sanction accrued and unpaid) and an investment portfolio of RMB51.4 billion outside the valuation.
- The SAMR imposed a RMB5,180 million penalty (confiscation plus fine, non-recurring) following a decision received on Jul 25, 2026, and a contra-revenue on accommodation that the release does not quantify or say whether it will recur; Q2 2026 grew 6% year over year and fell 3% versus Q1.
- The twelve-month net income remains inflated by RMB15.4 billion of 2025 gains from business acquisitions and the sale of long-term investments (of which MakeMyTrip accounts for RMB15.2 billion) that do not recur.
Intrinsic value — two valuation methods
By both methods, the value today (DCF $110 · Multiples $98) exceeds the market price ($41).
Pillars of the analysis
The verdict — today vs 5 years
Today — with margin of safety: at $41 trades ~58.7% below its value discounted to today (~$98) — the wide discount we require (≥38%, equivalent to a ~15% annual return); the risk is covered by the margin, not the rate.
At 5 years — Muy infravalorado: the target price ($123) plus dividends yield above the required average return (10%) — the business compounds.
The bridge: the return at 5 years comfortably exceeds the risk-free rate (4.5%) — and the discount reaches the required margin of safety.
Thesis
The business
An asset-light travel platform, with a network effect and four complementary brands, that grew +19.8% in 2024 and +17.1% in 2025 with a 25-27% operating margin, and that over the trailing twelve months to Jun 30, 2026 sustains a 24.0% margin excluding the fine. Return on invested capital is 12.7%, above the 10% bar, on a balance sheet carrying acquisition goodwill and an investment portfolio whose result is not in the numerator.
The valuation
It is valued by a multiple of operating income, which expenses stock-based compensation. The base case starts year 1 at +6%, the Q2 2026 rate, with a mild recovery to +7% by year 5, a 23.5-24.0% operating margin and a 17x exit multiple, within the online travel agency band. The five-year value per share is $123, with an estimated return of +25% at the market price.
The margin of safety
There is a margin of safety: the market's perception is meaningfully worse than reality. At $41 the stock trades at 8× its operating income excluding the penalty, with net cash of RMB47.9 billion (already net of the SAMR sanction accrued and unpaid at the semester close) and a long-term investment portfolio that is not paid for in the valuation. The status is Very undervalued; the adverse scenario, with 3-4% growth and a 21% margin, yields +25% annually.
What to watch
The Q2 2026 release states there was a contra-revenue imposed by the SAMR on accommodation, without quantifying it or saying whether it will recur; what is recurring is the obligation —ordered by the Jul 25, 2026 decision— to discontinue the exclusivity agreements and unreasonable conditions, whose effect on future commission has not yet been published. That effect needs to be watched in upcoming releases, along with whether growth stabilizes near the +6% of Q2 2026 or keeps falling in the quarterly sequence. If the operating margin excluding the sanction falls sustainably below the 21% of the adverse scenario, the thesis weakens.
Educational / informational. Does not constitute investment advice.
Valuation by multiples
The forward value is divided by the projected shares (fewer, after the buyback financed with cash flow), not today's — dividing the same value among fewer shares raises the value per share. This is the buyback modeled directly — the share-count path from the year-by-year model — not a piece added separately.
Discounted cash flow to present value (DCF)
Normalized owner earnings (RMB) as the base. Move the assumptions: the value recalculates live. The verdict remains anchored by multiples; the DCF contrasts it at present value.
Risk does not inflate the rate: protection is required separately, as a margin of safety over the value. The floor avoids discounting at the pace of a depressed market rate.
| Year | Projected FCF | Discount factor | Present value |
|---|---|---|---|
| 1 | CNY 14.8 bn | 0.957 | CNY 14.1 bn |
| 2 | CNY 15.8 bn | 0.916 | CNY 14.4 bn |
| 3 | CNY 16.8 bn | 0.876 | CNY 14.8 bn |
| 4 | CNY 18 bn | 0.839 | CNY 15.1 bn |
| 5 | CNY 19.2 bn | 0.802 | CNY 15.4 bn |
Reverse DCF — what growth the price discounts
The inverse approach: instead of projecting growth to obtain the value, the market price ($41) is taken as given and it solves for what annual owner-earnings growth would need to hold for 5 years for the present value —at the method's rate (4.5%, no-growth terminal)— to equal that price. It is the disconfirmation test: the expectations the price already pays for, contrasted against the method's projection.
The market discounts less growth (-18.5%/year) than we project (6.8%/year) → if the base case holds, there is margin: perception is more pessimistic than the estimated reality.
That growth implies ~CNY 5 bn of owner earnings in year 5 (vs ~CNY 19.2 bn of our base case). It recalculates if the DCF assumptions are edited.
Year-by-year model
Year-by-year projection of the selected scenario. From each year, two versions of the flow are derived: growth FCF (operating flow − total capex, the cash surplus) and maintenance FCF (the owner earnings: what the business yields if it only sustains its capacity). Cash accumulates the retained surplus —what is not returned as dividend or buyback—, so that EV falls and multiples compress going forward. The valuation is done on EV/EBIT. In edit mode, revenue, margins, capex, and exit multiples can be adjusted.
| CNY bn | TTM | +1a | +2a | +3a | +4a | +5a |
|---|---|---|---|---|---|---|
| Operation (editable: revenue, margins, capex, D&A) | ||||||
| Revenue | 65.708 | 69.65 | 74.177 | 79.369 | 84.925 | 90.87 |
| growth | — | +6% | +6% | +7% | +7% | +7% |
| OCF | 15.1 | 16.7 | 17.8 | 19.0 | 20.4 | 21.8 |
| OCF margin | 23.0% | 24.0% | 24.0% | 24.0% | 24.0% | 24.0% |
| Total capex | 0.797 | 0.87 | 0.93 | 0.99 | 1.06 | 1.14 |
| Maintenance capex | 0.4 | 0.4 | 0.5 | 0.5 | 0.5 | 0.6 |
| Growth capex | 0.4 | 0.4 | 0.5 | 0.5 | 0.5 | 0.6 |
| EBIT | 15.8 | 16.4 | 17.4 | 18.8 | 20.2 | 21.8 |
| EBIT margin | 24.0% | 23.5% | 23.5% | 23.7% | 23.8% | 24.0% |
| NOPAT | 13.4 | 13.9 | 14.8 | 16.0 | 17.2 | 18.5 |
| D&A | 0.823 | 0.86 | 0.91 | 0.97 | 1.03 | 1.1 |
| Cash flow (the two versions) | ||||||
| FCF growth (OCF − total capex) | 14.3 | 15.8 | 16.9 | 18.1 | 19.3 | 20.7 |
| FCF maintenance (OCF − maintenance capex) | 14.7 | 16.3 | 17.3 | 18.6 | 19.9 | 21.2 |
| Owner earnings (NOPAT + D&A − maintenance capex) | 13.8 | 14.3 | 15.3 | 16.5 | 17.7 | 19.1 |
| EV and multiples (the accumulated cash lowers EV) | ||||||
| Cash | 79.5 | 90.2 | 102 | 114 | 127 | 141 |
| EV (MktCap − Cash + Debt) | 118 | 108 | 96.2 | 84.0 | 71.0 | 57.0 |
| EV / FCF growth | 8.3x | 6.8x | 5.7x | 4.7x | 3.7x | 2.8x |
| EV / FCF maintenance | 8.0x | 6.6x | 5.6x | 4.5x | 3.6x | 2.7x |
| EV / Owner earnings | 8.6x | 7.5x | 6.3x | 5.1x | 4.0x | 3.0x |
| EV / NOPAT | 8.8x | 7.7x | 6.5x | 5.3x | 4.1x | 3.1x |
| EV / EBIT | 7.5x | 6.6x | 5.5x | 4.5x | 3.5x | 2.6x |
| EV / Sales | 1.8x | 1.5x | 1.3x | 1.1x | 0.8x | 0.6x |
| Shares and shareholder return | ||||||
| Shares (M · buyback/dilution) | 629.705 | 620.259 | 610.956 | 601.791 | 592.764 | 583.873 |
| net change (− buyback / + dilution) | — | -1.5% | -1.5% | -1.5% | -1.5% | -1.5% |
| Buyback in $ (current buyback, grows with FCF) | CNY 4.4 bn | CNY 4.9 bn | CNY 5.2 bn | CNY 5.5 bn | CNY 5.9 bn | CNY 6.3 bn |
| Value curve (value/share at exit multiple by year) | ||||||
| Value / share (target price) | — | CNY 570 | CNY 628 | CNY 699 | CNY 758 | CNY 822 |
| CAGR vs price | — | (+109%) | (+52%) | (+37%) | (+29%) | (+25%) |
Currency: Trip.com reports in renminbi (RMB) and trades in dollars on Nasdaq (1 ADS = 1 ordinary share). The entire model runs in RMB; the anchor market value was crossed at the convenience translation rate the 2Q2026 release itself uses as of Jun-30-2026 (US$1.00 = RMB6.785), and the record converts once, at the end, at the live exchange rate. Year-0 = twelve months as of Jun-30-2026 built by levels: FY2025 from the 20-F plus first-half 2026 minus first-half 2025 from the 6-K dated Sep-16-2026. Revenue RMB65,708 million (62,510 + 31,871 − 28,673). Operating income is normalized by excluding the SAMR antitrust penalty of RMB5,180 million (disgorgement of illegal gains of RMB1,658 million plus a fine of RMB3,521 million, 7.5% of 2025 PRC revenue, per the administrative decision dated Jul-25-2026) recorded in general expenses in 2Q2026, which is non-recurring: reported RMB10,591 million becomes RMB15,771 million (24.0% margin). The 2Q2026 release states that accommodation revenue was partly offset by a revenue offset imposed by SAMR but does not quantify it or say whether it recurs; what is recurring is the obligation — ordered by the decision — to cease the sanctioned conduct (exclusivity and unreasonable conditions) and to refund RMB122 million in discounted security deposits to hotels, whose effect on future commission is not disclosed. The release does not include a cash flow statement, so year-0 operating cash flow, capex, and free cash flow remain at FY2025 levels (RMB14,379, 797, and 13,582 million). Path: the 20-F does not provide annual guidance and the 2Q2026 release also does not publish numeric guidance, so year 1 does not start at the +11.2% for the half-year but at the 2Q2026 rate (+5.5% year-over-year, −3% versus 1Q on energy cost, geopolitical volatility, and operational adjustments): base case +6.0%, adverse +3.0%, favorable +8.0%. The shape is a dip and mild recovery (+6.0%, +6.5%, and +7.0% from year 3), declared under the rebound exception: the dip reflects macro factors the issuer itself describes as transitory, and the 7% terminal rate stays within the band for a quality business still growing, without returning to the 17-20% path of 2024-2025. Operating margin: starts from the 24.0% normalized figure and the 2Q2026 adjusted EBITDA margin deterioration (29% versus 33% a year earlier), 23.5% in years 1 and 2 and 24.0% by year 5; the adverse case assumes the remedy compresses margin to 21%. Maintenance capex = 50% of capex (method convention). Buybacks: the share count path is a single one across the three scenarios and reduces the count 1.5% per year, between the net reduction in FY2025 (653.3 to 649.6 million, −0.6%) and the drop in the 2Q basic average (659.9 million in 2Q2025 versus 632.3 million in 2Q2026, −4.2%), below the capacity given by free cash flow after the dividend. Year-0 count: 629.7 million, the point-in-time count as of Mar-31-2026 that the 20-F itself publishes in Item 6.E (629,705222,222 ordinary shares issued and outstanding as of March 31, 2026), the closest to the Jun-30-2026 ttmEnd — the 2Q2026 release only publishes weighted averages (632.3 million), and the 2025 year-end figure (649.6 million) is older; the convertible notes are subtracted as debt and not added to the denominator. Balance as of Jun-30-2026 from the release: cash, equivalents, and restricted cash RMB56,016 million plus short-term investments 23,499 (restricted cash is not published separately in the release; as of Dec-31-2025 it was RMB6.6 billion), against debt of RMB26,397 million plus RMB5,179 million of the SAMR penalty accrued and unpaid at half-year close (the decision is dated Jul-25-2026, after the close, so as of Jun-30-2026 it could not have been paid; other current liabilities rose RMB4,251 million during the half). With the penalty loaded as debt-type liability, the model's total debt is RMB31,576 million and net cash is RMB47,939 million. The long-term investment portfolio (RMB51,361 million) is left out of the cascade and shown as an optionality.
Today's elevated multiple is the price of growth: if the business grows, the entry point cheapens on its own going forward (the metric grows while EV stays roughly flat). The exit multiple at 3 years is higher than the terminal at 5 years —at 3 years there is more growth still ahead—, so the value curve shows whether value creation is concentrated in the early or the later years. The required return is applied to the base scenario.
Scenarios (bear / base / bull) — at 5 years
Value sensitivity
Value per share by growth scenario (rows) and the compression or expansion of the exit multiple (columns). The color shows whether it beats the required return.
| Growth ↓ / Multiple → | Compression−15% | Base multiple | Expansion+15% |
|---|---|---|---|
| AdverseRevenue +3% in year 1 and +4% after; the SAMR remedy compresses the operating margin to 21% · base 13x EV/EBIT | $68 10.8% | $80 14.4% | $92 17.7% |
| BaseRevenue +6% in year 1 (the Q2 2026 rate) · base 17x EV/EBIT | $104 20.7% | $123 24.7% · base case | $141 28.3% |
| FavorableRevenue +8% in year 1 and +9.5% from year 3; operating margin up to 25.5% · base 19x EV/EBIT | $133 26.7% | $156 30.9% | $179 34.6% |
Multiples — today
High today = growth is being paid for; they cheapen toward 3 and 5 years (see Projections).
Forward multiples
With today's price fixed and the metric growing, what multiple is being paid at 3 and 5 years. Today's high multiple is the price of growth: if the business grows, the entry multiple cheapens on its own.
Optionalities
They are valued separately, with their own rationale, and are not incorporated into the base or the verdict (they are excess return). When assigning them value — in Editmode —, the total with optionalities updates live, without moving the base.
The verdict, the base CAGR, and the margin of safety are always calculated on the base; optionalities do not alter them (with optionalities at $0 they do not move).
Maximum price to pay today — by required return
Each card fixes a required annual return and answers: if the business is worth $123 in 5 years, what is the maximum that can be paid today to obtain that return? Since it now trades at $41, the margin of safety is how much cheaper the market is than that maximum. The three thresholds: 4% covers inflation (the floor), 10% is the long-term average return, and 15% is the level of a great investment.
Return and margin of safety calculator
The maximum price to pay today to earn the required return, with the dividend collected as a separate flow. Both controls are editable.
With a target price of $123 in 5 years and a required return of 4.5% annually, the maximum to pay today is $98. Against the current market price ($41), the margin of safety is 58.7% (trades below the maximum → there is margin) and the total return at that price would be 24.7% annually.
Valuation quality
- Entry multiple. 8× operating income excluding the fine, with net cash, below the floor of its exit band.
- Estimated return. +25% annually over five years in the base case (Very undervalued).
- Assets outside the valuation. A long-term investment portfolio of RMB51.4 billion that is not paid for.
ROIC vs the 10% bar — the compounding engine
The quality bar — return bands
The return on capital is judged against absolute bands; the value-creation floor is the market's opportunity cost (~10%). A stock's volatility does not measure business risk.
ROIC 13% → good (10-15%). The bar is a measure of business quality, not the method's discount rate: value is discounted to today at the risk-free rate, and protection is required separately, as a margin of safety.
Owner earnings — the waterfall
It charges maintenance capex (which EBITDA does not deduct). The growth capex (CNY 0.4 bn) is voluntary and is not charged to the base — it depresses FCF today, creates value tomorrow.
Cash & reinvestment
Margins — trajectory
Each margin over sales, year by year: historical (solid line) → projection (dotted).
Owner earnings — the detail
Business quality
- ✓ ROIC exceeds the cost of capital (~10%)
- ✓ CFROIC backs up the ROIC (103%, cash vs. accruals)
- ✓ Healthy balance sheet (low corporate debt)
- ✓ Durable competitive moat (multiple advantages)
Quality — cash · ROIC · reinvestment
- Operating margin. 25-27% in 2023-2025 and 24.0% excluding the fine in the twelve months to Jun 30, 2026.
- Return on capital. 12.7% on total invested capital, above the 10% bar; higher on operating capital excluding the investment portfolio.
- Cash conversion. 2025 operating cash flow (RMB14.4 billion) came in below operating income due to working-capital consumption; the Q2 2026 release does not include a cash flow statement.
Revenue trajectory
Values in CNY bn. The % over each bar is the year-over-year (YoY) growth — each year, historical and projected, vs the prior one (the TTM vs the TTM from a year ago). The path comes from the same source as the table; years without their own series in the model are interpolated between the anchors. Historical solid, projection in a lighter shade.
Where the growth comes from · by segment
Weight in revenue and year-over-year (YoY) growth, in reported CNY.
Share of first-half 2026 revenue and growth versus the first half of 2025, in RMB million: accommodation 11,766 to 13,086, transportation 10,815 to 11,400, packaged tours 2,026 to 2,291, corporate travel 1,265 to 1,461 and other 2,801 to 3,633. Accommodation remains the engine, and since Q2 2026 it carries the contra-revenue imposed by the SAMR.
Growth engine — operating drivers
Annual levels from the official filing (10-K); the % over each bar is the year-over-year (YoY) growth vs the prior year.
In a travel agency, revenue is booked volume times commission rate. The 20-F reports booked-volume growth by line (accommodation +17%, transportation +6% in 2025) but not the commission rate; the gap between revenue growth and volume growth in both lines (21% versus 17% and 11% versus 6%) indicates higher monetization per booked unit in 2025. From Q2 2026 that monetization in accommodation is affected by the contra-revenue imposed by the SAMR. Amounts are in RMB.
Projections
| Metric | FY23 | FY24 | FY25 | TTM | +1A | +2A | +3a | +4A | +5a |
|---|---|---|---|---|---|---|---|---|---|
Revenue | CNY 44.6 bn | CNY 53.4 bn (+20%) | CNY 62.5 bn (+17%) | CNY 65.7 bn | CNY 69.7 bn (+6%) | CNY 74.2 bn (+6%) | CNY 79.4 bn (+7%) | CNY 84.9 bn (+7%) | CNY 90.9 bn (+7%) |
Operating income (EBIT, excluding the SAMR fine) | CNY 11.3 bn | CNY 14.2 bn (+25%) | CNY 15.8 bn (+11%) | CNY 15.8 bn | CNY 16.4 bn (+4%) | CNY 17.4 bn (+6%) | CNY 18.8 bn (+8%) | CNY 20.2 bn (+7%) | CNY 21.8 bn (+8%) |
Net income attributable | CNY 9.9 bn | CNY 17.1 bn (+72%) | CNY 33.3 bn (+95%) | CNY 24.2 bn | CNY 21.6 bn (-11%) | CNY 19.3 bn (-11%) | CNY 17.2 bn (-11%) | CNY 18.5 bn (+7%) | CNY 19.8 bn (+7%) |
Stock-based compensation | CNY 1.8 bn | CNY 2 bn (+11%) | CNY 2.3 bn (+11%) | CNY 2.6 bn | CNY 2.7 bn (+7%) | CNY 2.9 bn (+7%) | CNY 3.1 bn (+7%) | CNY 3.3 bn (+6%) | CNY 3.5 bn (+6%) |
The % are the annual (year-over-year) growth: each year —historical and projected— vs the prior one; the TTM (trailing 12m) vs the TTM of a year ago, to avoid overlapping windows. The historicals are exact figures from the official filings; the projected years come from the year-by-year model (the intermediate years without their own series are interpolated between the anchors). The projected columns (+1y…+5y) are 12-month windows counted from the TTM close (30-jun-2026): the projection starts from the most recently reported data, not the fiscal year. The projected base is realistic and unbiased — the risk discount is applied at the end, via the required return. The rationale for each metric is in the (i).
Growth quality
- Revenue trajectory. +19.8% in 2024, +17.1% in 2025 and +11.2% in the first half of 2026.
- Monetization per booked unit. Revenue grew faster than booked volume in accommodation and transportation in 2025; from Q2 2026 the SAMR contra-revenue weighs on accommodation.
- 2026 trend. From +17% in Q1 2026 to +6% in Q2 2026, with a 3% sequential decline and no numerical guidance.
Moat strength
The business and its moat
What it does and how it makes money
Trip.com Group aggregates the offering of hotels, airlines, trains, buses, ferries and tour operators and sells it through four brands: Ctrip, Qunar, Trip.com and Skyscanner. In accommodation and air tickets it acts as agent on virtually all transactions; it recognizes the accommodation commission when the booking becomes non-cancellable and the transportation commission when the ticket is issued, making the model asset-light: 2025 capex was RMB0.8 billion on RMB62.5 billion of revenue.
The engine is booked volume times commission. In 2025 accommodation grew 21% to RMB26.1 billion, in line with booked volume up 17%; transportation grew 11% to RMB22.5 billion with volume up 6%. In the first half of 2026 accommodation added RMB13.1 billion (+11%) and transportation RMB11.4 billion (+5%). Packaged tours, corporate travel and other services round out the mix. More than 90% of orders are executed through mobile channels.
Scale and competitive position
The company describes itself as the go-to destination for travelers in Asia. At the close of 2025 it offered about 1.7 million accommodations, flights from more than 680 airlines and more than 350,000 in-destination activities, with a transportation network covering more than 220 countries and regions. Trip.com operates in 27 languages and 44 currencies, and the group maintains about 6,000 physical stores in China as a complementary channel.
Scale also shows up on the balance sheet: as of Jun 30, 2026 it held RMB100.5 billion between cash, restricted cash and short-term investments (of which RMB21.0 billion are time deposits and financial products that instead appear on the balance sheet under the long-term investments line, which totals RMB51.4 billion and also includes the remaining stake in MakeMyTrip).
The moat: why it is hard to compete
The advantage stems from the network effect: breadth of supply attracts users and the user base attracts more suppliers, which is the dynamic the 20-F itself describes. Add to that brand recognition across four distinct consumer entry points, sustained technology investment (more than 1,100 patents registered in China, more than 880 invention patents, and more than 1,850 registered trademarks; the company states it does not depend on any single patent) and the review content and loyalty program accumulated since 1999.
In China, moreover, operating online requires value-added telecommunications licenses with restrictions on foreign ownership, which forces variable interest entity (VIE) structures. The 20-F itself, however, characterizes the sector's barriers to entry as relatively low: it acknowledges that the evolution of artificial intelligence could lower them further and that a competitor could replicate or improve on the functions the company offers.
Moat direction and threats
The moat is rated stable: volume is growing, but the filings show no measured unit-economics gap that is widening, and scale alone does not prove direction. The 20-F acknowledges that hotels and airlines are pushing direct sales, that content platforms, social networks and AI assistants can divert traffic, that some competitors have more resources, and that the sector's barriers to entry are relatively low.
The regulatory threat has already materialized: the SAMR investigation for alleged abuse of dominant position, opened in January 2026, resulted in an administrative decision received on Jul 25, 2026 that makes up the RMB5,180 million penalty as a confiscation of illegal gains of RMB1,658 million plus a fine of RMB3,521 million (7.5% of 2025 revenue in the PRC), orders the return of RMB122 million in deposits withheld from hotels, and orders that exclusivity agreements and unreasonable conditions be discontinued (Art. 22(4) and (5)). The penalty is non-recurring; the Q2 2026 release states there was a contra-revenue on accommodation but does not quantify it or say whether it will recur, and that is what bears watching. Add to this the reliance on VIEs and the risk of a U.S. delisting if the PCAOB cannot inspect the auditor.
Business / sector quality
- Capital-light agency model. Charges a commission without owning inventory; capex of RMB0.8 billion on RMB62.5 billion of revenue in 2025.
- Network effect. Broad supply that attracts users and users that attract suppliers, across four brands.
- Demand recurrence. Travel is recurring, but sensitive to energy costs and geopolitical volatility, as Q2 2026 shows.
- Regulatory exposure in China. VIE structure, SAMR fine and contra-revenue on accommodation.
Solvency margin
Each pillar between danger and solid — the further right, the more room.
The cushion against the contraction phase of the cycle: the further right each pillar sits, the more room before solvency is compromised.
Net cash position
Cash + liquid investments − debt. The backstop that supports the balance sheet during the contraction phase of the cycle.
Debt composition
Not all debt is equal: only the structural needs refinancing; the rest is operational (self-liquidating).
Structural debt is what is exposed to the contraction phase of the cycle; operational debt (leases, matched funding) self-liquidates with the business.
Company health / solvency
- ✓Leverage (net debt / EBITDA)Net cash $47.9 bn
- ✓Interest coverage (EBIT / interest)29.8x
- !Liquidity (current ratio)1.33×
- ✓Cash quality (CFROIC vs ROIC)CFROIC backs 103% of ROIC
- !Value creation (ROIC − 10% bar)+3pp
- ✓Malinvestment test (capex vs incremental ROIC)Capex/D&A 1.0x — no over-investment
- –Float / working capitalNeutral WC
- !Dilution (SBC % of revenue + shares)SBC 3.9% of revenue
A traffic-light interpreted by the method (not generic): float (negative WC) adds up, capex is judged by incremental ROIC (malinvestment test), and a lender is not subjected to corporate solvency. The (i) shows the derivation of each number.
Health — balance sheet risks
- Net cash. RMB47.9 billion of net cash as of Jun 30, 2026, with restricted cash included and net of the SAMR sanction accrued and unpaid (RMB5,179 million).
- Debt profile. RMB25.8 billion of debt is due in the short term; covered by cash.
Who runs it
- Capital-return policy adopted in November 2023: buybacks and a discretionary annual dividend since 2024.
- Dividend of US$0.30 per share declared in February 2025 (about US$200 million).
- Buyback authorization of up to US$5.0 billion in August 2025.
- Sale of about 34.4 million MakeMyTrip Class B shares back to MakeMyTrip for about US$3,000 million (closed in July 2025), with a gain of RMB15.2 billion; after the transaction the stake stood at ~17%. The aggregate fiscal 2025 line for gains from business acquisitions and the sale of long-term investments was RMB15.4 billion, of which MakeMyTrip accounts for RMB15.2.
Capital allocation — indicators
Shares — ownership and dilution
Who owns the shares — the alignment and whether there is a controlling shareholder.
Minimal dilution: SBC represents less than 2% of value per year and the share count is ~flat — it does not erode value per share.
Management / capital allocation
- Leadership continuity. Co-founder as executive chairman and CEO since 2016.
- Capital-return policy. Buyback of RMB4.4 billion and dividend of RMB1.4 billion in 2025; the Q2 2026 basic share count fell 4.2% year over year.
- Deleveraging. Debt fell from RMB39.6 billion (2024) to RMB26.4 billion as of Jun 30, 2026.
- Dilution from stock-based compensation. RMB2.6 billion in the twelve months to Jun 30, 2026, 3.9% of revenue; expensed in the metric.
Why it is cheap
- Motivated sellers around a named regulatory event: the SAMR investigation opened in January 2026 ended in a decision received on Jul 25, 2026 (a RMB1,658 million confiscation plus a RMB3,521 million fine, RMB5,180 million in total, non-recurring) recorded in Q2 2026, and in a contra-revenue on accommodation that the release does not quantify; excluding the sanction, the Q2 2026 operating margin was 23.7%, without the permanent deterioration the price appears to be discounting.
- A slowdown verified in the Q2 2026 release: revenue +6% year over year and −3% versus Q1, with the adjusted EBITDA margin at 29% versus 33% a year earlier, with no numerical guidance for the rest of the year.
- A misleading earnings comparison: 2025's includes RMB15.4 billion in gains from business acquisitions and the sale of long-term investments (RMB15.2 billion from MakeMyTrip) and Q2 2026's includes a loss from the sanction, so reported earnings overstate the deterioration of the operating business.
- A jurisdiction discount: the VIE structure, broad PRC government oversight and the risk of a U.S. delisting keep away investors who cannot or will not hold Chinese issuers.
The stock's decline has an identifiable cause in the filings: the SAMR sanction (a RMB5,180 million fine and a contra-revenue on accommodation) and the Q2 2026 slowdown reported in the Sep 16, 2026 release. At $41 the price implies 8× operating income excluding the fine, well below the 15x floor of its band, as if the network effect had stopped producing margin; Q2 2026 still shows revenue +6% and an operating margin excluding the fine of 23.7%.
Return asymmetry — risk/reward
The annual return (CAGR at 5 years) in each scenario, with the total period return below — the margin of safety made visual: upside range wide, downside range narrow.
Even in the bear scenario, the return holds at +14%/year (+96% total): the margin of safety protects the downside. The bull (+31%/year, +284% total) exceeds it comfortably — a favorable asymmetry, with a narrow downside range and a wide upside range.
Bear case — disconfirmation
- If the contra-revenue imposed by the SAMR on accommodation, or the effect of having to discontinue the exclusivity agreements and unreasonable conditions, turns out to be persistent and large, it could compress the operating margin below 21%, beyond the non-recurring sanction already recognized; neither the release nor the decision quantifies it.
- The sequential Q2 2026 decline (−3% versus Q1, transportation −12%) is not a macro-driven trough but the start of a sustained low-single-digit growth rate.
- A hardening between the United States and China forces the delisting of the ADSs, with a loss of liquidity for the New York holder.
- The RMB5,179 million sanction had not been paid as of Jun 30, 2026 —the SAMR decision is dated Jul 25, 2026, after the semester close— and remains accrued as a liability; the model's net cash already nets it out (RMB47.9 billion).
Bull case — the thesis for
- The SAMR contra-revenue turns out to be limited and, with the sanction already recognized, the focus returns to growth in domestic and outbound travel.
- International Trip.com sustains double-digit growth and raises the revenue mix outside China.
- The US$5,000 million buyback authorization is executed at depressed prices: the Q2 2026 basic share count is already 4.2% lower than a year earlier.
- The RMB51.4 billion investment portfolio is partially monetized, as happened with MakeMyTrip.
Risks — what breaks the base case
- SAMR antitrust remedy. A RMB5,180 million penalty (confiscation plus fine, non-recurring) by decision dated Jul 25, 2026, with an order to return RMB122 million and discontinue the exclusivity agreements; the Q2 2026 contra-revenue on accommodation is not quantified.
- US delisting. Risk under the HFCAA if the PCAOB cannot inspect the auditor.
- Dependence on the VIE structure. The core China business operates through contractual arrangements.
- Currency. Value is generated in RMB and the price is paid in dollars.
Lenses — the value investing thinkers
Each thinker's analytical framework applied to our data.
Full alignment: both the business and the price work in your favor.
- Buffett / Graham Quality + margin of safety
A wide moat and ROIC 13% above the 10% bar, with a +59% margin → a quality business at a good price.
- Peter Lynch Growth at a reasonable price (GARP)
A stalwart growing 7% at a multiple/growth of 1.2 → cheap for its growth.
- Joel Greenblatt Cheap and high-return (Magic Formula)
Earnings yield 13% (EBIT/EV) + ROIC 13% → brushes the Magic Formula.
- Howard Marks Perception vs reality + cycle
The price discounts -19% vs our 7%: perception is more pessimistic than reality, with an identified source of the discount.
- Seth Klarman Capital protection (bear scenario)
Bear-scenario floor +14%/yr, bull-scenario ceiling +31%/yr over 5y and a +59% margin → capital protected, asymmetry in your favor.
- Pat Dorsey Moat strength (Five Rules)
A wide moat, stable; sources: network effects, intangibles, efficient scale, cost advantage, switching costs → passes the Five Rules.
- Aswath Damodaran Expectations implied by the price
Justifying the price requires discounting -19%, within what we project (7%) — the story squares with the numbers.


