Revolut Business and CRS: what gets reported and how to plan it

US LLC outside CRS when routed through Revolut Technologies Inc. and Lead Bank; the EU Revolut Bank UAB product is a different perimeter. We explain the distinction and how to plan it.

Revolut Business held by a US LLC should not be treated as a European CRS account: for a US LLC it runs under Revolut Technologies Inc. with Lead Bank, without an EU IBAN and outside CRS. Revolut Bank UAB for European personal or EU business customers is a different product and is inside CRS.

Revolut can be useful, but the product perimeter matters: Revolut Business for a US LLC (Revolut Technologies Inc. + Lead Bank, no CRS) is not the same as Revolut Bank UAB for European customers (CRS). Mixing those two realities makes the article sound technical while missing the point.

CRS 2.0, CARF and DAC8 update (OECD package)

Revolut Bank UAB is a Lithuanian credit institution fully inside CRS since day one; what shifts for your LLC's Revolut Business account with the OECD package is tighter due diligence on controlling persons and the explicit inclusion of electronic-money products under the new CRS 2.0 perimeter.

The OECD adopted an integrated package combining CRS 2.0 (the revised Common Reporting Standard, which brings EMIs and specified electronic-money products into the perimeter and tightens due diligence on controlling persons) and CARF (the Crypto-Asset Reporting Framework, which extends automatic exchange to crypto exchanges, custodians and crypto-derivative platforms). The European Union transposed it through Directive (EU) 2023/2226 (DAC8), adopted on 17 October 2023, which amends Directive 2011/16/EU to incorporate both components. The substantive application date is 1 January 2026 and the first effective exchange lands in January 2027, covering the prior reporting-year data.

Official sources: OECD — CRS, OECD — CARF, EUR-Lex — Directive (EU) 2023/2226 (DAC8).

The takeaway to remember is the same as always: the United States stays outside the CRS perimeter by architecture, not by opacity. Washington runs its own regime (FATCA), did not sign CRS 1.0 and will not sign CRS 2.0 — which is exactly why your US LLC remains a fully declarable structure in your country of residence. We unpack the full picture in CRS 2.0 and CARF: why the US will never sign and what it means for your LLC.

Which Revolut entities operate and where they report

Revolut is not a single company. The group operates through several regulated entities:

• Revolut Bank UAB (Lithuania): bank with full license from the Bank of Lithuania (Lietuvos Bankas) and EU passport. The principal entity for European Economic Area customers since 2021. Reports CRS to the Valstybinė mokesčių inspekcija (VMI) Lithuanian tax authority, which then activates bilateral exchange with AEAT, SAT, DIAN, AFIP and other authorities.
• Revolut Ltd (UK): EMI regulated by the FCA. After Brexit, the UK retained its own CRS regime and continues exchanging with the EU. Reports to HMRC.
• Revolut Payments UAB: Lithuanian EMI for payments operations within the EEA.
• Revolut Technologies Inc. (United States): the US group entity under which Revolut Business is offered to clients with a US LLC, with Lead Bank as US banking partner. Lead Bank is a US federally chartered bank and therefore sits outside CRS (the US is not a CRS participant); the applicable reporting regime is FATCA, not CRS.
• Subsidiaries in Singapore, Australia, the US and other markets with their own regulators.

Practical consequence: if you open Revolut Business as a Spanish, Mexican, Colombian or Argentine customer, your account is normally under Revolut Bank UAB (Lithuania) and information flows via the Lithuanian VMI to the country of tax residence stated in your CRS self-certification.

Applicable regulatory framework

• OECD: Common Reporting Standard 2014, with updated official commentaries.
• EU: Directive 2011/16/EU (DAC) amended by DAC2 (Directive 2014/107/EU), which internalises CRS in Union law.
• Lithuania: Law on automatic exchange of financial account information for tax purposes, national CRS and DAC2 implementation.
• Spain (receiving): Royal Decree 1021/2015, Form 720, Form 721 (already in force) for crypto-assets. See details in our article on CRS for residents in Spain and LATAM.

What information Revolut sends

Like any Reporting Financial Institution under CRS, Revolut Bank UAB reports annually:

Revolut does not send detail transaction by transaction: it sends annual aggregates. But the year-end balance is enough for the AEAT to detect whether you cross the Form 720 threshold (€50,000) or the Form 721 threshold if you have linked crypto holdings.

The case of an LLC with a Revolut Business account

Critical point. If your US LLC opens a Revolut Business account as a European customer (typically with an operational European address, card delivery in Europe or representative in Europe), Revolut runs CRS due diligence on the entity (the LLC) and, unless it can classify the LLC as Active NFE with robust documentation, treats it as a Passive NFE.

What does that imply? That Revolut is required by CRS rules to identify the controlling persons (you, as owner of the LLC) and to report:

• The LLC's data to its country of tax residence (US, which does not participate in CRS, so the data sits in VMI Lithuania with no active recipient in the US).
• The controlling persons' data to the country of tax residence of each controlling person. That is: to your tax authority if you are resident in Spain, Mexico, Colombia, Argentina, etc.

This means that, even though the LLC is American, the data on your ownership and the account balance reaches your national tax authority. The US-not-CRS barrier does not protect the information if the operational account sits in Europe.

Active vs Passive NFE classification

Revolut will ask you to complete a CRS Self-Certification form when you open the account. There you declare whether the LLC is Active NFE or Passive NFE, who the controlling persons are, and the entity's tax residence(s).

An Active NFE is one in which less than 50% of its income is passive (dividends, interest, rents, non-operational royalties, investment gains) and less than 50% of its assets produce or are held to produce passive income. A typical professional services LLC invoicing advisory or development meets the Active NFE criteria.

In practice, Revolut tends to apply conservative criteria and, when in doubt or with insufficient documentation, classifies as Passive NFE. The consequence is the same: it reports to the beneficial owner.

What if you misdeclare residence

If you declare "tax residence in Andorra" upon opening but Revolut detects indicia that you live in Spain (recurring IP, card delivery address, Spanish phone number, periodic transfers to Spain), it will apply the change in circumstances procedure: it will request a tax residence certificate or, failing that, report you to both jurisdictions. False self-certification can be a tax infringement and, depending on the case, a criminal offense.

How to plan properly with Revolut Business

1. Don't use Revolut as the LLC's primary account if you want to minimize CRS footprint to your home country. There is no automatic primary account anymore; Relay or Slash often make more sense operationally, Wise Business handles international movement, and Mercury fits only when US nexus and continuity risk are acceptable. Revolut makes sense as a secondary account for specific needs (physical European cards, fast EUR/GBP conversion, SEPA debit).
2. If you use Revolut, declare correctly and prepare for the data to arrive. It's the only professional approach. We develop this in how to design a solid international structure.
3. Maintain documentary consistency. Your CRS self-certification, your Form 720 (or LATAM equivalent) and your IRPF (or local equivalent) must tell the same story.
4. Know the risks. If you misdeclare, consequences materialize late but they arrive, as we explain in tax risks of bad international structuring.
5. Mind your closing balance schedule. Revolut reports the 31 December balance. If you don't want unnecessary Form 720 triggers, manage your closing balance with operational criteria, not "concealment" (which is illegal).

Quick comparison: Revolut vs Mercury vs Wise vs CRS

We expand the Wise comparison in our dedicated Wise and CRS article.

Additional considerations: DAC7 and DAC8

If your LLC sells through digital platforms (Amazon, Etsy, Airbnb, SaaS marketplaces), DAC7 adds an information channel parallel to and complementary with CRS: platforms report your income directly to European tax authorities. And if you operate with crypto-assets through European exchanges, DAC8 activates the CRS-equivalent for crypto from today.

In summary

Revolut Business is an excellent tool, but understanding its CRS reporting profile is essential if you have an LLC and you reside in a CRS-adhering country. The key is not to avoid Revolut, but to declare correctly and design the stack so that the information reported is consistent with what you pay.

Want to review your banking stack and understand exactly what reaches your tax authority, and how to declare it correctly? book your strategic review.

Tax compliance in your country: CFC, controlled-foreign rules and income attribution

A US LLC is a fully legal, internationally recognized vehicle. But compliance does not end at incorporation: as an owner who is tax-resident elsewhere, your local tax authority still has the right to tax what the LLC earns. The key is under which regime.

By jurisdiction

• Spain (LIRPF/LIS). An operative single-member disregarded LLC (real services, no significant passive income) is generally treated under income attribution (art. 87 LIRPF): the LLC's net profits are attributed to the member in the year they arise and integrated into the general IRPF base. If instead the LLC elects corporation treatment (Form 8832) and is controlled by a Spanish resident with mostly passive income, the CFC regime (art. 91 LIRPF for individuals, art. 100 LIS for companies) can apply. The choice is not optional: it depends on economic substance, not on the label.
• Information returns. US bank accounts with average or year-end balance >€50,000: Form 720 (Law 5/2022 after CJEU C-788/19, 27/01/2022, penalties now under the general LGT regime). Related-party transactions and dividend repatriation: Form 232. US-custodied crypto: Form 721. At Exentax we have reduced difficult exposure in cases like this. Speaking early changes the file before it turns expensive.
• Spain–US tax treaty. The treaty (BOE 22/12/1990, Protocol in force 27/11/2019) governs double taxation on dividends, interest and royalties. An LLC without a permanent establishment in Spain does not by itself create a PE for the member, but effective management can if all activity is run from Spanish territory.
• Mexico, Colombia, Argentina and other LATAM jurisdictions. Each has its own CFC regime (Mexico: Refipres; Argentina: foreign passive income; Chile: art. 41 G LIR). Common principle: profits retained inside the LLC are deemed received by the member if the entity is treated as transparent or controlled.

> Apply this to my situation

Price without structure gets expensive

Numbers help, but they do not protect. An LLC filed without professional guidance can end up with no IRS calendar, a missed Form 5472, weak KYC and a restricted bank account when profile, use or US nexus is not documented.

At Exentax we review tax residence, real activity, nexus, Mercury/Relay/Slash/Wise banking and the IRS calendar before anything moves. The goal is an LLC that invoices, keeps banking access and survives review.

Practical rule: an operative LLC with substance, properly declared in your country of residence, is legitimate tax planning. An LLC used to hide income, fake non-residence or shift passive income with no economic justification falls within art. 15 LGT (anti-abuse) or, worse, art. 16 LGT (simulation). The facts decide, not the paperwork.

At Exentax we structure the entity to fit the first scenario and document every step so your local return can be defended in case of review.

Banking and tax facts worth clarifying

Fintech and CRS information evolves; here is the current state:

Notes by provider

• Mercury operates with several federally chartered partner banks and FDIC coverage via sweep network: mainly Choice Financial Group and Evolve Bank & Trust, with Column N.A. still in some legacy accounts. Mercury is not itself a bank; it is a fintech platform backed by those partner banks. If Mercury closes an account, the balance is typically returned by paper check mailed to the account holder's registered address, which can be a serious operational problem for non-residents; keep a secondary account (Relay, Wise Business, etc.) as contingency.
• Wise ships two clearly different products: Wise Personal and Wise Business. For an LLC you must open Wise Business, not the personal account. Important CRS nuance: a Wise Business held by a US LLC sits outside CRS because the account holder is a US entity and the US is not a CRS participant; the USD side operates via Wise US Inc. (FATCA perimeter, not CRS). In contrast, a Wise Personal opened by an individual tax-resident in Spain or another CRS jurisdiction does trigger CRS reporting via Wise Europe SA (Belgium) on that individual. Opening Wise for your LLC does not bring you into CRS through the LLC; a separate Wise Personal in your own name as a CRS-resident individual does report.
• Wallester (Estonia) is a European financial entity with an EMI/issuing-bank licence. Its European IBAN accounts are within the Common Reporting Standard (CRS) and therefore trigger automatic reporting to the tax administration of the holder's country of residence.
• Payoneer operates through European entities (Payoneer Europe Ltd, Ireland) that are also in scope for CRS for clients resident in participating jurisdictions.
• Revolut Business: when paired with a US LLC, it operates under Revolut Technologies Inc. with Lead Bank as its US banking partner. The account delivered is a US account (routing + account number); no European IBAN is issued to a US LLC. The European IBANs (Lithuanian) belong to Revolut Bank UAB and are issued to European clients of the group. If you are offered a European IBAN tied to your LLC, confirm exactly which legal entity holds that account and which regime it reports under.
• Zero tax: no LLC structure delivers "zero tax" if you live in a country with CFC/tax transparency or income attribution rules. What you achieve is no double taxation and correct reporting at residence, not elimination.

We set it up without you losing a weekend

Thousands of freelancers and entrepreneurs already operate their US LLC legally, with documentation and a clear compliance file. At Exentax we handle the entire process: formation, banking, payment gateways, bookkeeping, IRS filings and compliance in your country of residence. Book a strategic review and we will tell you honestly whether the LLC makes sense for your case, with no absolute promises.

(2026) case study: Revolut Business, LLC and CRS

A US LLC opens Revolut Business under Revolut Technologies Inc. + Lead Bank: it receives USD routing and account number, not a European IBAN. That profile is not CRS-reported because the US does not participate in CRS. If the same person opens a personal or European business profile under Revolut Bank UAB as a Spanish tax resident, that account is inside CRS and the tax authority receives identification, year-end balance and reportable income where applicable; not daily movements. Pillar Two does not affect a small single-owner LLC.

Official sources updated (2026):

• OECD — Common Reporting Standard

Revolut Business and CRS: what it reports to your tax authority and how it looks from the other side

Revolut Business is practical, multi-currency and cheap - and reports systematically under the Common Reporting Standard like any European bank. If you open Revolut Business for your LLC thinking "it is fintech, not a bank" and therefore does not report, you are wrong. Here is what is sent, when and how the data appears at your tax office.

• CRS regime of Revolut Business. Revolut Bank UAB (the entity hosting Revolut Business EU) is a CRS reporting financial institution since its Lithuanian banking licence. It reports annually to the Bank of Lithuania, which shares with the rest of CRS jurisdictions - including the beneficial owner's declared tax residence. Spain, France, Italy, Germany, Portugal receive the data each year.
• Exact data transmitted. Holder identification (Revolut knows the UBO via KYC: name, ID/passport, address, declared tax residence at onboarding), balance at 31 December, reportable gross income and proceeds where applicable, and account identifier (LT IBAN of Revolut Business). Individual transactions are NOT transmitted, aggregates are.
• Why your tax office cross-checks with 720. Spain requires Form 720 if the sum of foreign accounts exceeds €50,000 on 31/12 or last-quarter average balance. If your Revolut Business has €60k and you do not file 720, the tax office receives the data via CRS and compares. Difference = automatic case with imputation sanction (50% of amount) and interest.
• What changes vs traditional US bank. Revolut Business EU reports CRS automatically and fast (Q1 of next year). Mercury and Wise USD report FATCA to IRS and, via bilateral exchange with your country, it also arrives but with more latency. Operationally: Revolut accelerates the tax office's visibility on your LLC; Mercury slows it but does not eliminate it.

What we are asked the most

If I open Revolut Business as US LLC, does it report to US or my country? Reports to declared UBO tax residence. If you said Spain at KYC, it goes to Spain via CRS, not US (the LLC is disregarded for UBO; the individual behind matters).

Can I declare residence "US" at KYC to avoid reporting to my country? False declaration to the bank - documentary false declaration offence. Additionally Revolut requests documentation supporting declared residence (utility bill, tax certificate). Not a path.

At Exentax we structure the LLC's banking stack considering what CRS and FATCA report to your residence and plan the declarations (720, 3916, RW) so automatic cross-checks do not open a case.

References: sources on structures and jurisdictions

The comparisons and quantitative data on the jurisdictions cited here rely on official sources updated to today:

• United States. Delaware General Corporation Law and Limited Liability Company Act, Wyoming Limited Liability Company Act (Title 17, Chapter 29), IRS Form 5472 instructions and IRC §7701 (entity classification).
• Andorra. Llei 95/2010 de l'Impost sobre Societats (10% IS), Llei 5/2014 del IRPF and the active/passive residency framework of the Govern d'Andorra.
• Estonia. Estonian Income Tax Act (deferred-distribution corporate tax at 20/22%) and official documentation of the e-Residency programme.
• Spain. Ley 27/2014 (IS), Ley 35/2006 (IRPF, arts. 8-9 on residency and art. 100 on CFC) and the inbound-expat regime (art. 93 LIRPF, "Beckham Law").
• OECD. Pillar Two (GloBE) and OECD Model Tax Convention with Commentaries.

Choosing a jurisdiction always depends on the holder's actual tax residency and on the economic substance of the activity; review your specific case before taking any structural decision.

_More on this topic: LLC in the United States: complete guide for non-residents._

• Wise IBAN with your LLC: what actually gets reported to the tax office
• CRS and your US LLC bank accounts: what is shared with your home country
• DAC8 and crypto: the new automatic tax reporting that arrives in 2026
• Form 5472: what it is, who must file it and how to comply

What if HMRC, the IRS or my local tax authority asks about my LLC?

It's the question every client raises in the first consultation, and the short answer is: your LLC isn't opaque, and a properly declared structure closes any inquiry in standard forms. Your tax authority can request the state Certificate of Formation (Wyoming, Delaware or New Mexico), the EIN issued by the IRS, the signed Operating Agreement, the Mercury or Wise statements for the year, the Form 5472 plus pro-forma 1120 you filed, and the bookkeeping that reconciles income, expenses and movements. If all of that exists and is delivered in order, the inquiry doesn't escalate.

What tax authorities do pursue, and rightly, is sham ownership (nominees, paper residency) and undeclared foreign accounts. A well-structured LLC is the opposite: you appear as beneficial owner in the BOI Report when applicable (verifiable at fincen.gov/boi), you sign the bank accounts and you declare the income where you actually live. The structure is registered with the state Secretary of State, with the IRS and, when European banks are involved, inside the CRS perimeter of the OECD standard.

The mistake that really sinks an inquiry isn't having an LLC; it's not attributing the income correctly in your domestic return, not declaring foreign accounts when the year-end balance exceeds the local threshold (€50,000 in Spain via Modelo 720; the equivalent FBAR / Form 8938 in the US for residents; T1135 in Canada), and not documenting related-party transactions between the member and the LLC. Those three fronts are worth closing before any request arrives, not after.

## What an LLC does NOT do

- It does not exempt you from tax in your country of residence. If you live in Spain, France, Germany or Portugal, you are taxed there on worldwide income. The LLC organises your US side (zero federal tax for non-resident SMLLC pass-through, absent Effectively Connected Income); it does not switch off your domestic taxation. The income tax is computed on the attributed profit, not on the dividends actually paid.

- It is not an offshore vehicle or a BEPS scheme. It is a US entity recognised by the IRS, registered in a specific state with physical address, registered agent and annual informational filings. Classic offshore jurisdictions (BVI, Belize, Seychelles) leave no public trace; an LLC leaves a trace in five different places.

- It does not protect you if you commingle funds. The pierce the corporate veil doctrine kicks in as soon as a judge sees the LLC and the member behaving as the same wallet: mixed accounts, personal expenses paid from the LLC, no signed Operating Agreement, no bookkeeping. Three suspicious transactions are enough.

- It does not save you social security contributions at home. If you are self-employed in Spain, France or Germany, your monthly social contribution remains identical. The LLC handles the trading side with international clients; your personal contribution is independent.

- It does not exempt you from declaring foreign accounts. Spain residents file Modelo 720 / 721; UK residents, the SA106; Portugal residents, the Anexo J of Modelo 3 IRS; Germany residents, the Anlage AUS. Those obligations belong to the individual, not to the LLC.

At Exentax we cover those five fronts every year alongside the US federal calendar (Form 5472, pro-forma 1120, FBAR, state Annual Report and BOI Report when applicable). The goal is that no inquiry finds a loose end and that the structure withstands a 5-to-7-year retroactive review.

What CRS actually moves between countries

CRS does not push every transaction line over the wire. It moves a

defined record per reportable account once a year: account holder

identity, balance at year-end, gross interest, gross dividends, and

gross proceeds for accounts that hold securities. Movements between

your own accounts, the granular invoice list, and operational notes

stay inside the bank. The receiving tax administration gets a tidy

summary, not a payment statement.

This matters when reading your Revolut Business profile, because the

question is not "what does Revolut see"; it is "what record will

Revolut hand to my tax authority once a year, and does that record

match what I will declare myself".

If you read those five lines next to your own annual declaration and

they tell the same story, the CRS report is a non-event. If they

diverge, that is where the reconciliation work belongs.

Three real Revolut Business + CRS scenarios

A Spanish tax-resident running a US LLC kept a Revolut Business

account in EUR for occasional EU client invoices. The end-of-year

balance was small and the cash flow modest. The CRS report matched

the LLC's bookkeeping cleanly because the member treated Revolut as

an ordinary working account rather than a treasury vehicle.

A digital agency with two members, one in Portugal and one in

Germany, ran a single Revolut Business account. The reporting went

to both home countries proportionally to the declared beneficial-

owner share, and we reconciled member draws against the K-1-style

allocation each member declared at home. No surprises.

A advisor who briefly parked a large advance in Revolut Business

saw the December snapshot trigger a follow-up question from the home

tax office the next spring. The fix was a one-page note attaching

the contract that justified the advance, the matching invoice, and

the subsequent service delivery. The advance was already declared,

so the question closed quickly.

Mistakes that turn a calm CRS report into a noisy file

• Treating Revolut Business as a savings account. The 31 December

snapshot is what feeds the report; large idle balances become

conversation starters.

• Operating both a personal Revolut and a Revolut Business under the

same email mental model. They are reported separately and the

matching to your declarations must be separate.

• Forgetting the residence change. If the member's tax residence

shifted mid-year, the bank's CRS profile must shift in time;

otherwise the report goes to the wrong country.

• Ignoring the soft annual review that Revolut does. A short

proactive update on activity is cheaper than a reactive question

later.

Reconciliation checklist with your declaration

• Identify the closing balance in account currency on 31 December.
• Convert at the official year-end rate used in your home country.
• Add interest received during the year, if any.
• Confirm the figure appears in your annual filing (Modelo 720/721

in Spain when applicable, or the equivalent in your jurisdiction).

• Keep the supporting screenshots in the LLC's compliance folder.

We treat CRS as a calm annual postcard, not a search warrant.

Aligned profiles and aligned declarations make the postcard the

thinnest part of the year.