GST guide

GST on export of services: zero-rated — if you meet all five conditions

SaaS companies, agencies, GCCs and freelancers billing foreign clients can export services without GST. Miss one condition and it becomes an 18% domestic supply.

The five conditions (section 2(6), IGST Act)

  1. The supplier is in India.
  2. The recipient is outside India.
  3. The place of supply is outside India.
  4. Payment is received in convertible foreign exchange (or in rupees where RBI permits, such as Special Rupee Vostro accounts).
  5. Supplier and recipient are not merely establishments of the same person — a foreign parent or subsidiary is a separate person and qualifies.

All five must be met; there’s no partial export.

Export without paying IGST: the LUT

  • File a Letter of Undertaking in Form GST RFD-11 on the GST portal, valid for one financial year — before your first export of the year (most file by 31 March for the next year).
  • Almost every registered business is eligible; the bar is prosecution for evasion above ₹250 lakh.
  • Alternatively, pay IGST and claim it back as a refund.

Getting input tax credit back

  • Exporting under LUT leaves unused ITC: claim it in RFD-01 using the formula zero-rated turnover × net ITC ÷ adjusted total turnover.
  • Time limit: two years from the relevant date.
  • Keep bank evidence of foreign-currency receipts (e-FIRA / e-BRC) — courts have held refunds can’t be denied where these are produced.

2026 change for intermediaries

From 30 March 2026 the Finance Act 2026 removed the special place-of-supply rule for intermediary services. Indian businesses that arrange or facilitate supplies for foreign clients now follow the default rule — the recipient’s location — so they can qualify as exporters if all five conditions are met.

Don’t forget FEMA

Export proceeds must be realised within the period FEMA prescribes — the export-import regulations were revised in 2026, so confirm the current period with your bank. GCCs and SaaS exporters: see GCCs in India and AI startups.

Frequently asked questions

Is GST charged on export of services?
No, if all five conditions in section 2(6) of the IGST Act are met — supplier in India, recipient outside India, place of supply outside India, payment in convertible foreign exchange (or permitted rupees) and not merely establishments of one person. Exports are zero-rated.
What is LUT in GST?
A Letter of Undertaking in Form GST RFD-11 that lets you export goods or services without paying IGST. It's filed online each financial year before the first export.
Can intermediaries export services after 2026?
Yes. From 30 March 2026 the special place-of-supply rule for intermediaries was removed, so they follow the recipient's location and can qualify as exporters if all conditions are met.

Please note: this guide is general information based on the rules as they stood on the review date above. Regulations and RBI/CBDT procedures change often — please get advice on your specific facts before acting.

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