Is an LUT mandatory for exporting services?

No. An LUT, or a bond, is only needed if you want to export without paying IGST. Without either, you charge IGST, pay it, and claim a refund.

How long is an LUT valid?

For the financial year in which you file it. It expires on 31 March, so file a new one for the next financial year before your first export invoice in it.

Can I invoice a foreign client in US dollars?

Yes. Show the dollar amount, the exchange rate and the rupee taxable value. For services, rule 34(2) says to use the rate given by generally accepted accounting principles for the date of the time of supply. Agree the rate method with your CA.

What happens if the foreign client pays late?

Under an LUT, if payment hasn't arrived 15 days after the later of one year from the invoice date or the FEMA period, you pay the IGST with interest (rule 96A). The FEMA period for services is nine months from the invoice date, or twelve if invoiced or settled in rupees, and your bank can extend it.

Is billing my company's own office abroad an export?

No. An establishment in India and one abroad of the same person are distinct persons, and section 2(6)(v) excludes supplies between them. An Indian subsidiary billing its foreign parent can qualify, because they are separate companies (Circular 161/17/2021-GST).

Which SAC code do I use for a software or design agency?

Commonly 998314 for IT design and development, 998313 for IT consulting and support, 998361 for advertising and 998391 for specialty design. Pick the code that matches the service you invoiced, and confirm it with your CA.

GST invoicing · Export of services · India

GST invoice for export of services under LUT: format, exact wording and a worked example

If you bill a client outside India and the service qualifies as an export, it is zero-rated. File a Letter of Undertaking (LUT) in Form GST RFD-11 for the financial year, then invoice with no IGST and print the rule 46 export declaration. Without an LUT or a bond (Form RFD-11 covers both), you charge IGST and claim it back as a refund.

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LUT in Form RFD-11 · Rule 46 declaration · IGST s.2(6) · Last reviewed 29 Oct 2026

This page is general information only and isn't tax advice. GST and FEMA rules change, so check your export invoices with your CA.

Is your service an export? The five conditions

Section 2(6) of the IGST Act calls a supply of services an export only when all five of these are true:

IGST Act section 2(6): the five conditions for an export of services
#	Condition (IGST Act s.2(6))	What it means for an agency or consultancy
(i)	The supplier is located in India	You bill from your Indian registration
(ii)	The recipient is located outside India	The client contracting with you is abroad
(iii)	The place of supply is outside India	Usually true for remote work for a foreign client (see the next section for exceptions)
(iv)	Payment is received in convertible foreign exchange, or in Indian rupees wherever RBI permits	USD, EUR, GBP and so on, or INR through a route RBI allows (see "When the money must arrive")
(v)	You and the client are not merely establishments of a distinct person	Billing your own branch or head office abroad does not count; billing a separate company in your group can

Two points that trip people up

Branch vs subsidiary. An Indian branch of a foreign company billing its own head office is the same legal person, so it fails condition (v). An Indian subsidiary is a separate company from its foreign parent, so its services to the parent can be an export if the other four conditions are met (CBIC Circular 161/17/2021-GST).
Intermediaries. Until 29 March 2026, section 13(8)(b) put the place of supply of intermediary services (brokers, agents who arrange a supply between others) in India, so they could not be exports. The Finance Act, 2026 omitted that clause with effect from 30 March 2026. Intermediary services now follow the general rule in section 13(2), unless an exception in 13(3) to 13(5) applies. For work that spans 30 March 2026, check the time of supply with your CA.

If any condition fails, the invoice is a normal taxable supply. Our GST invoice format for services covers that case.

Place of supply when the client is abroad

Section 13 of the IGST Act decides the place of supply when either side is outside India. The default, in section 13(2), is the location of the recipient. So for most remote design, development, marketing or consulting work for a foreign client, the place of supply is the client's country.

The exceptions matter for some agencies:

Services on goods the client sends you (13(3)(a)): place of supply is where the work is done.
Services that need the client, or someone acting for them, to be physically present with you (13(3)(b)): place of supply is where the service is performed. A workshop you run for the client's team in Bengaluru is in India.
Services tied to immovable property (13(4)) and events (13(5)): where the property is, or where the event is held.
If the client's location isn't available in the ordinary course of business, the place of supply is your location (13(2) proviso).

Two ways to bill an export

Exports are zero-rated under section 16 of the IGST Act. You then have two routes.

Exporting services with an LUT or on payment of IGST
Point	With an LUT	Without an LUT
IGST on the invoice	None	IGST charged, usually 18% for the heading 9983 services in the SAC table below; confirm the rate for your service with your CA
Declaration on the invoice	"...UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX"	"...ON PAYMENT OF INTEGRATED TAX"
Cash flow	No tax paid out	You pay the IGST, then claim a refund in Form GST RFD-01
What you can refund	Unutilized input tax credit (s.16(3))	The IGST you paid (s.16(4))
Proof needed for a refund	BRC or FIRC for each invoice (rule 89(2)(c))	BRC or FIRC for each invoice

A refund application has to be filed within two years of the "relevant date" (section 54(1) of the CGST Act). For services exported, that is the date payment is received, or the invoice date if you were paid in advance (section 54, Explanation 2(c)). Section 16(4) lets the Government specify which goods or services may use the pay-and-refund route. As of 29 Oct 2026, Notification 01/2023-Integrated Tax, as amended by 05/2023, allows all services and excludes only certain goods such as pan masala, tobacco and mint oils. Rules change, so check your case with your CA before choosing it.

The LUT: Form GST RFD-11

What it is. A Letter of Undertaking lets you export without paying IGST. In it, you promise to pay the tax with interest if the export conditions aren't met in time (rule 96A(1)).

Who can file. Every registered person who wants to export without paying IGST, except someone prosecuted under the CGST Act, IGST Act or earlier tax laws where the tax evaded is more than ₹250 lakh. That person files a bond with a bank guarantee instead (Notification 37/2017-Central Tax; Circular 8/8/2017-GST).

How long it lasts. One financial year. An LUT is valid for the whole financial year in which it is tendered, and on the GST portal its status changes to "Expired" at the end of that year. File a fresh one each year, before your first export invoice of that year (Circular 8/8/2017-GST; GST portal LUT FAQ).

Approval. CBIC told officers to accept an LUT within three working days. If nothing happens in that time it is deemed accepted, and the portal shows "Deemed Approved" (Circular 8/8/2017-GST, para 2(e); GST portal LUT FAQ).

How to file it on the GST portal:

Log in and go to Services > User Services > Furnish Letter of Undertaking (LUT).
Pick the financial year. Your GSTIN and legal name are filled in.
Enter the name, address and occupation of two independent witnesses.
Tick the self-declarations.
Preview, then sign with DSC or EVC. The signatory is the working partner, managing director, proprietor or a person they authorize.
You get an ARN and an acknowledgement by SMS and email. Track it under Services > User Services > View My Submitted LUTs.

No LUT in place?

Then a zero-rated export has to go out on payment of IGST, and you claim that IGST back as a refund. File the LUT before you invoice; the portal FAQ says it is furnished "before affecting such supply". Where exports were made before the LUT was filed, CBIC has told officers the delay may be condoned case by case (Circular 125/44/2019-GST, para 44). Treat that as a safety net and don't plan around it.

What the export invoice must show

An export invoice is a normal rule 46 tax invoice with three changes: the export declaration, the foreign recipient's details in place of the clause (e) details, and the country of destination.

Rule 46 fields on an export invoice for services
Field	Source	On an export invoice for services
Your name, address, GSTIN	Rule 46(a)	Always
Invoice number, up to 16 characters, unique for the financial year	46(b)	Always
Date	46(c)	Always
Recipient name and address	Export proviso, (i)	The foreign client's legal name and address
Address of delivery	Export proviso, (ii)	For services, usually the client's address
Country of destination	Export proviso, (iii)	The client's country
SAC code	46(g)	See the next section
Description	46(h)	Say what you did and for which period
Total value and taxable value	46(j), (k)	See "Currency and exchange rate"
Rate and amount of tax	46(l), (m)	Nil under an LUT; IGST if you pay tax
Place of supply	46(n)	Outside India, naming the country
Reverse charge	46(p)	"No"
Signature or digital signature	46(q)	Not needed on an electronic invoice issued in accordance with the IT Act, 2000
QR code with IRN	46(r)	Only if e-invoicing applies to you
Export declaration	Rule 46, export proviso	Exact wording below

The exact declaration wording

Rule 46 says an export invoice "shall carry an endorsement" in one of two forms, as the case may be.

With an LUT (no IGST paid):

SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX

Paying IGST:

SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS ON PAYMENT OF INTEGRATED TAX

You'll often see a shorter line, "SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX". That is the wording before Notification 17/2017-Central Tax (27 July 2017) replaced it. Lines like "under LUT without payment of IGST" are paraphrases. Print the current rule text. You can also add your LUT ARN and financial year next to it so anyone checking the invoice can match it to your LUT.

SAC codes agencies and consultancies use

From the GST Council's scheme of classification of services:

SAC codes for agency and consultancy services (GST Council scheme of classification)
SAC	Service
998311	Management consulting and management services, including financial, strategic, HR, marketing, operations and supply chain
998312	Business consulting services, including public relations
998313	IT consulting and support services
998314	IT design and development services
998361	Advertising services
998391	Specialty design services, including interior, fashion and industrial design
998393	Scientific and technical consulting services
998395	Translation and interpretation services

How many digits: Notification 78/2020-Central Tax asks for 4 digits if your aggregate turnover in the previous year was up to ₹5 crore, and 6 digits above that. Up to ₹5 crore, it also lets you leave the code off invoices to unregistered persons, which a foreign client usually is. We'd still print the full 6-digit SAC: a 6-digit code meets either minimum, and it describes the service on the invoice you will later match with your bank remittance. Your CA can confirm the code and the digits for your services.

Currency and exchange rate

You can invoice a foreign client in their currency. GST values, though, are reported in rupees, so the invoice should show both.

Which rate. Rule 34(2) of the CGST Rules: for services, use the rate of exchange "determined as per the generally accepted accounting principles" for the date of the time of supply. The RBI reference rate you see recommended online was the original 2017 rule for services; Notification 17/2017-Central Tax replaced it from 27 July 2017.
What to print. The foreign-currency amount, the rate you used and its date, and the rupee taxable value. Use the same method on every invoice and agree it with your CA.
The money that arrives may differ from the invoice rupee value because the rate on the day of receipt is different. That difference is an accounting question for your CA. The invoice itself stays as issued.

E-invoicing for exports

If your aggregate turnover in any financial year from 2017-18 onwards has been more than ₹5 crore and you aren't in an exempt category, e-invoicing applies to you, and it covers supplies "for exports" as well as supplies to registered persons (Notification 13/2020-Central Tax as amended; threshold from Notification 10/2023-Central Tax). Some types of business are exempt under Notification 13/2020 as amended, for example banks, insurers and goods transport agencies. Your export invoice then needs an IRN and the QR code from the e-invoice system. Below the threshold, you issue the invoice as usual.

When the money must arrive, and how you prove it

Payment is part of the definition of an export of services (condition (iv)), so the deadline matters for GST as well as for FEMA.

GST deadline under an LUT (rule 96A(1)(b)). If payment hasn't been received in convertible foreign exchange, or in rupees where RBI permits, you must pay the IGST with interest within 15 days after whichever is later:

one year from the invoice date, or
the period allowed under FEMA, including any extension RBI permits.

The Commissioner can allow further time. This wording came in through Notification 12/2024-Central Tax.

FEMA deadline. Under RBI's Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026, export proceeds for services must be realized and repatriated within nine months from the invoice date. If the export is invoiced or settled in rupees, it's twelve months. Your bank (the Authorised Dealer) can extend this if you give reasons.

If you miss the GST deadline. Notification 37/2017-Central Tax says that if you don't pay the tax and interest in time, your LUT facility is treated as withdrawn. It comes back once you pay. In between, exports have to go out on payment of IGST or under a bond with a bank guarantee (Circular 8/8/2017-GST, para 2(b)). CBIC has also said the Commissioner can extend the time limit after the event, and that the same principle applies to services (Circular 125/44/2019-GST, para 45).

Which receipts count. Payment received in convertible foreign exchange meets condition (iv) of section 2(6). CBIC Circular 202/14/2023-GST accepts rupee proceeds through a Special Rupee Vostro Account. Circular 263/09/2026-GST, dated 26 October 2026, adds repatriable rupee accounts such as SNRR and INR Nostro, and set-off of export receivables against import payables done as RBI directs.

Proof. For a refund on an export of services, rule 89(2)(c) asks for a statement of invoice numbers and dates with the matching Bank Realisation Certificates (BRC) or Foreign Inward Remittance Certificates (FIRC). The GST portal asks for the BRC or FIRC number for each invoice, and one invoice can carry several. DGFT also runs an electronic BRC (e-BRC) system: banks send your inward remittance details to DGFT, and you self-certify e-BRCs against them on the DGFT website. Since 13 January 2026 the e-BRC format carries your GSTIN, GST invoice number and GST invoice date (DGFT Public Notice 42/2025-26), so it helps to quote the GST invoice number your client sees on the remittance request too. Keep these even if you never claim a refund, because they show condition (iv) was met.

Worked example: a Pune agency billing a US client

All names, numbers and the exchange rate below are example values, made up for illustration.

Supplier: Example Studio LLP, Pune, Maharashtra. GSTIN 27AAAAA0000A1Z5 (example).
Client: Example Corp Inc., Austin, Texas, USA. Not registered in India.
Work: website design and development, Sprint 4, delivered remotely, 1 to 31 October 2026.
Fee: USD 4,000.
LUT for FY 2026-27: filed and approved, ARN AD2704260000000 (example).
Exchange rate used: ₹88.00 per USD (example rate only; use the rate your method gives for the date).

Check the conditions first. Supplier in India: yes. Client outside India: yes. Place of supply: no exception applies (remote work, no goods, no presence needed), so the client's location, USA (s.13(2)). Payment: will come in USD. Distinct person: separate companies, so condition (v) is met. This is an export.

Invoice under the LUT

FieldExample value

Invoice no. and dateES/26-27/0142, 16 Nov 2026

SupplierExample Studio LLP, [address], Pune, Maharashtra. GSTIN 27AAAAA0000A1Z5

RecipientExample Corp Inc., [address], Austin, Texas, USA

Address of deliverySame as recipient

Country of destinationUnited States of America

Place of supplyOutside India (USA)

DescriptionWebsite design and development, Sprint 4 (1 to 31 Oct 2026)

SAC998314

AmountUSD 4,000.00

Exchange rate₹88.00 per USD as on 16 Nov 2026 (example)

Taxable value₹3,52,000.00

IGSTNil

TotalUSD 4,000.00 (₹3,52,000.00)

Reverse chargeNo

DeclarationSUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX. LUT ARN AD2704260000000, FY 2026-27

SignatureAuthorized signatory

The maths: USD 4,000 × ₹88.00 = ₹3,52,000. IGST under the LUT: nil.

The same invoice without an LUT: IGST at 18% on ₹3,52,000 = ₹63,360. The declaration changes to the "ON PAYMENT OF INTEGRATED TAX" form. You pay ₹63,360 in your return and later claim it back in Form GST RFD-01 with the BRC or FIRC. Whether the client pays that IGST on top of USD 4,000 depends on your contract.

The deadlines for this invoice

FEMA: realize USD 4,000 within nine months of 16 Nov 2026, that is by 16 Aug 2027, unless your bank extends it.
GST (rule 96A): the later of one year (16 Nov 2027) and the FEMA period (16 Aug 2027) is 16 Nov 2027. Add 15 days: if the money still hasn't arrived, IGST of ₹63,360 plus interest is due by 1 Dec 2027. For your own invoices, confirm these dates with your CA.

Common mistakes

Printing a shortened declaration. Use the rule 46 text above.
Invoicing before the LUT for the new financial year is filed. LUTs expire at the end of each financial year.
Treating a branch or head office abroad as a foreign client. It fails condition (v).
Assuming every foreign client means an export. A workshop the client attends in India, or an event held in India, has its place of supply in India.
Using the RBI reference rate because a template said so. Rule 34(2) points to your accounting method for services.
Losing track of BRC or FIRC numbers. You need them for every refund, and they prove you were paid.
Assuming the intermediary change covers every open contract. For work that spans 30 March 2026, check the time of supply with your CA.

Where Trakkar fits

Trakkar is time tracking, attendance and project-margin software for Indian service businesses, used by 100+ teams. Agencies use it to:

Track time by project in the Windows and macOS desktop apps
See each project's margin and a health badge (On track / Margin thin / Loss) on its Budget tab once you set a project value
Send quotes, follow them from sent to accepted to invoiced, and raise GST invoices for your Indian clients with the client's GSTIN and numbering that resets each Indian financial year
Record TDS when you log a payment

We don't list export invoices, foreign-currency amounts, exchange rates, the LUT declaration or SAC codes as Trakkar features, so prepare your export invoices with your CA. Trakkar doesn't file GST returns or generate e-invoice IRNs.

Pricing is ₹120/user/month + GST on one plan, with a 14-day free trial and no credit card. See Trakkar pricing or book a 30-minute demo. For agency-specific features, see time tracking software for agencies. For domestic clients, use our GST invoice format for services and the free GST invoice template.

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Sources

Last reviewed 29 Oct 2026. Sources: IGST Act ss.2(6), 13, 16; CGST Rules 34, 46, 89, 96A; CGST Act s.54; Notifications 17/2017, 37/2017, 78/2020, 13/2020, 10/2023, 12/2024 and 04/2026 (Central Tax); Notification 11/2017-Central Tax (Rate); Notifications 01/2023 and 05/2023 (Integrated Tax); DGFT Public Notice 42/2025-26 and DGFT's eBRC page; CBIC Circulars 8/8/2017, 125/44/2019, 161/17/2021, 202/14/2023 and 263/09/2026; Finance Act, 2026 s.157; RBI FEMA 23(R)/2026-RB. This is general information only and isn't tax advice. Check your invoices with your CA.