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INCOME TAXES
9 Months Ended
Sep. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
 
Income tax expense consists of U.S. and international income taxes, determined using an estimate of the Company's annual effective tax rate, which is based upon the applicable tax rates and tax laws of the countries in which the income is generated. A deferred tax liability is recognized for all taxable temporary differences, and a deferred tax asset is recognized for all deductible temporary differences and operating loss and tax credit carryforwards. A valuation allowance is provided when it is more likely than not that some portion or all of a deferred tax asset will not be realized. The Company considers many factors when assessing the likelihood of future realization of the deferred tax assets, including its recent cumulative earnings experience by taxing jurisdiction, expectations of future income, tax planning strategies, the carryforward periods available for tax reporting purposes, and other relevant factors.

The Company's effective tax rates for the three and nine months ended September 30, 2025 were 20.8% and 20.0%, respectively, compared to 12.3% and 16.0% for the three and nine months ended September 30, 2024, respectively. The Company's 2025 effective tax rates differ from the U.S. federal statutory tax rate of 21%, primarily due to the benefit of the Netherlands Innovation Box Tax (discussed below) and U.S. state income taxes, partially offset by higher international tax rates, certain non-deductible expenses, and U.S. federal and state tax associated with the Company's international earnings. The Company's 2024 effective tax rates differed from the U.S. federal statutory tax rate of 21%, primarily due to the benefit of the Netherlands Innovation Box Tax and a reduction to the Company's 2018 federal one-time deemed repatriation liability, pursuant to the U.S. Tax Cuts and Jobs Act ("Tax Act"), resulting from a U.S. Tax Court decision in Varian Medical Systems, Inc. v. Commissioner, partially offset by higher international tax rates, unrecognized tax benefits, and U.S. federal and state tax associated with the Company's international earnings.

The Company's effective tax rate for the three months ended September 30, 2025 was higher than the effective tax rate for the three months ended September 30, 2024, primarily due to the reduction to the Company's 2018 federal one-time deemed repatriation liability, pursuant to the Tax Act, that was recorded in 2024 and resulting from a U.S. Tax Court decision in Varian Medical Systems, Inc. v. Commissioner, and non-deductible goodwill impairment charges relating to KAYAK, partially offset by certain higher discrete tax benefits and certain lower non-deductible expenses.
The Company's effective tax rate for the nine months ended September 30, 2025 was higher than the effective tax rate for the nine months ended September 30, 2024, primarily due to the reduction to the Company's 2018 federal one-time deemed repatriation liability, pursuant to the Tax Act, that was recorded in 2024 and resulting from a U.S. Tax Court decision in Varian Medical Systems, Inc. v. Commissioner, and non-deductible expenses related to the convertible senior notes, partially offset by certain higher discrete tax benefits and certain lower non-deductible expenses.

In July 2025, the One Big Beautiful Bill Act ("BBB Act") was enacted into law in the United States. The BBB Act made changes to certain international, foreign tax credit, and domestic tax provisions in the United States effective in 2025 and 2026. There was not a significant impact to the Company's income tax expense or effective tax rate for the three and nine months ended September 30, 2025 as a result of the BBB Act.

During the three and nine months ended September 30, 2025 and 2024, a majority of the Company's income was reported in the Netherlands, where Booking.com is based. According to Dutch corporate income tax law, income generated from qualifying innovative activities is taxed at a rate of 9% ("Innovation Box Tax") rather than the Dutch statutory rate of 25.8%. A portion of Booking.com's earnings during the three and nine months ended September 30, 2025 and 2024 qualified for Innovation Box Tax treatment, which had a beneficial impact on the Company's effective tax rates for these periods.

The aggregate amount of unrecognized tax benefits for all matters at September 30, 2025 and December 31, 2024 was $239 million and $260 million, respectively. As of September 30, 2025, net unrecognized tax benefits of $228 million, if recognized, would impact the effective tax rate. As of September 30, 2025 and December 31, 2024, total gross interest and penalties accrued was $5 million and $6 million, respectively. The decrease in unrecognized tax benefits primarily relates to the settlement by Booking.com of certain Italian tax matters (see Note 13). The majority of unrecognized tax benefits are included in "Other assets, net" in the Unaudited Consolidated Balance Sheet as of September 30, 2025. It is reasonably possible that the balance of gross unrecognized tax benefits could change over the next twelve months.