SecProbe.io

Mail Stop 4561
September 30, 2016

Xiaofan Wang
Chief Financial Officer
Ctrip.com International, Ltd.
99 Fu Quan Road
Shanghai 200335
People’s Republic of China

Re: Ctrip.com International, Ltd.
 Form 20 -F for Fiscal Year Ended December 31, 2015
Filed April 22, 2016
File No. 001 -33853

Dear Ms. Wang :

We have reviewed your letter dated September 23, 2016  in connection wi th the above -
referenced filing  and have the following comments.  In some of our comments, we may ask you
to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the request ed information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing  any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.   Unless otherwise noted, where
prior comments are referred to they refer to our letter dated September 9, 2016 .

Notes  to Consolidated Financial Statements

Note 2.  Principal Accounting Policies

Acquisitions, page F -18

1. We note in your response to prior comment 7 that goodwill recognized in the Qunar
acquisition is primarily made up of expected synergies.  Given the sig nificant amount of
goodwill recognized in this transaction, please explain further the specific synergies you
identified, the relative significance of each, and revise to include such discussion in your
future filings.

Xiaofan Wang
Ctrip.com International, Ltd.
September 30, 2016
Page 2

 Note 15. Taxation, page F -41

2. We not e the table provided as part of your response to prior comment 9.  Please reconcile
the pretax income totals for fiscal 2013 and 2014 to the amounts presented in the
Consolidated Statements of Income and Comprehensive Income .

3. We note your response to  prior comment 10 provides information with regards to the tax
rate differential and non -deductible expense line items for fiscal 2015.  Please provide a
breakdown of such line items for fiscal 2014 and explain the reasons for the significant
variance from fiscal 2014 to 2015.

Form 6 -K Filed September 6, 2016

4. You state in your response to prior comment 12 that the equity method of accounting for
your investment in Homeinns is still appropriate since you continue to hold
approximately  15% of the equity and there are common directors serving on the boards of
both companies.  A review of Exhibit 99.1 of Homeinns’  Form 6 -K filed on April 1,
2016, suggests that BTG acquired approximately 66% of Homeinns ’ outstanding
ordinary shares   Therefore , please explain further the basis for your conclusion that you
continue to exercise significant influence over the operating and financial policies of
Homeinns as defined in ASC 323 -10-15.  As part of your response, please describe the
composition of Homeinn s’ board and tell us how you determined that your two board
seats provide  you the ability to exercise significant influence over the operating and
financial policies of Homeinn s.  Also, address the level of influence exerted by BTG by
virtue of t heir voting interest.

You may contact Frank Knapp, Staff Accountant at (202) 551 -3805  if you have questions
regarding comments on the financial statements and related matters.  If you require further
assistance, do not hesita te to contact me at (202) 551 -3499 .

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief
Office of Information Technologies
and Ser vices