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<Research>UBS: TRIP.COM-S (09961.HK) Monopoly Investigation May Result in Fines of Max. RMB3.9B
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TRIP.COM-S (09961.HK) is under investigation by the State Administration for Market Regulation (SAMR) for alleged monopolistic behaviors, according to UBS' research report.

Reviewing past industry cases, the focus of such investigations typically centers on exclusive cooperation behaviors. For instance, in the case of BABA-W (09988.HK), the investigation targeted its '2-choose-1' exclusive trading rule, which restricted merchants from operating on other competing platforms.

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The MEITUAN-W (03690.HK) case involved investigations into indirect implementation of exclusive cooperation behaviors, including differentiated commission rates, delayed merchant onboarding, technological enforcement through data and algorithmic tools and the collection of merchant deposits.

Penalties may include fines, implementation of remedial measures, administrative guidance and ongoing compliance obligations. If fined, the amount is typically 3-4% of prior-year domestic revenue, within the 1-10% range stipulated by China's Anti-Monopoly Law.

It is estimated that TRIP.COM-S may face fines ranging from RMB392 million to RMB3.9 billion, equivalent to 2-18% of its FY2026 non-GAAP net profit.

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