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

Revolut Business for a US LLC can sit in the Revolut Technologies Inc. and Lead Bank perimeter; EU Revolut Bank UAB is different. Plan the entity, holder and reporting logic.

Revolut requires separating 2 perimeters: Revolut Business for a US LLC under Revolut Technologies Inc. + Lead Bank is not a European CRS account; Revolut Bank UAB is for EU customers.

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 and a US account profile. 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, US/FATCA profile) 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 for Revolut Business and CRS

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: <a href="https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/" target="_blank" rel="noopener nofollow">OECD — CRS</a>, <a href="https://www.oecd.org/tax/exchange-of-tax-information/crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.htm" target="_blank" rel="noopener nofollow">OECD — CARF</a>, <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2226" target="_blank" rel="noopener nofollow">EUR-Lex — Directive (EU) 2023/2226 (DAC8)</a>.

For Revolut Business, reporting depends on the account perimeter: provider entity, business use, self-certification, UBO data, payment behaviour and the country where the owner is tax resident. A US LLC does not automatically make a European EMI account private, and a European product should not be confused with a US bank account. We unpack the broader privacy layer in <a href="/en/blog/crs-carf-and-us-banking-privacy-for-llc-owners">CRS, CARF and US banking privacy for your LLC</a>.

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; the right analysis is US/FATCA perimeter, KYC/AML and legal-access channels, not European 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

• <a href="https://www.oecd.org" target="_blank" rel="noopener">OECD</a>: 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.

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 <a href="/en/blog/international-tax-design-3-jurisdictions-max-no-cfc">how to design a solid international structure</a>.
3. Maintain documentary consistency. Your CRS self-certification, your Form 720 (or LATAM equivalent) and your IRPF (or local equivalent) must stay aligned.
4. Know the risks. If you misdeclare, consequences materialize late but they arrive, as we explain in <a href="/en/blog/international-tax-risks-cfc-banking-and-ownership">tax risks of bad international structuring</a>.
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 <a href="/en/blog/wise-business-and-crs-for-us-llc-owners">dedicated Wise and CRS article</a>.

Additional considerations: DAC7 and DAC8

If your LLC sells through digital platforms (Amazon, Etsy, Airbnb, SaaS marketplaces), <a href="/en/blog/dac7-reporting-for-digital-platforms-and-llc">DAC7</a> 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, <a href="/en/blog/dac8-crypto-and-llc-eu-reporting-under-control">DAC8</a> activates the CRS-equivalent for crypto from today.

Identify the contracting entity and account holder first

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.

For CRS analysis, the decisive details are the product, contracting entity, account holder, residence declarations and whether the account is personal or genuinely business.

Exentax turns those details into one documented banking decision: which product fits the LLC, how the account should be described, what evidence supports the activity and how the reporting position connects with the owner's country of residence.

> <a href="/en/book">Review my case</a>

For Revolut Business, the analysis starts with the contracting entity and product perimeter. A European bank or EMI product, a US business account and a personal account are not the same reporting story.

For Revolut Business, the decisive questions are account entity, business or personal use, tax self-certification, payment narrative and where the owner is actually resident. The provider name alone does not determine the reporting outcome.

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

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 stay aligned, 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.