Export of Services GST — LUT Filing Guide for Indian Consultants and Developers

For Indian consultants, developers and creative professionals selling services to overseas clients, the Letter of Undertaking (LUT) is the single most important compliance document after your GST registration. This guide walks through exactly when you qualify, how to file, and what to do every year after.

1. Who qualifies as an "exporter of services"

Section 2(6) of the IGST Act lays down five conditions: supplier in India, recipient outside India, place of supply outside India (Section 13 IGST), payment in convertible foreign exchange, and supplier and recipient are not mere establishments of the same person. Miss any one and the supply is not an export.

2. Section 16(1) — the zero-rating mechanic

Once you qualify, Section 16(1) IGST treats the supply as zero-rated. You either (a) supply under an LUT or bond without payment of IGST, or (b) pay IGST and claim a refund under Section 54 CGST. Both routes preserve your ITC. The LUT route gives zero cash outflow and avoids the refund queue.

3. LUT eligibility

Any registered taxpayer can file an LUT, provided they have not been prosecuted for any offence under the CGST/IGST Act or any earlier law where the tax evaded exceeds Rs2.5 crore (per the original Notification 37/2017 and its successors). Almost every freelancer and consultant qualifies.

4. Step-by-step LUT filing on the GST portal

• Log in at gst.gov.in.
• Navigate: Services → User Services → Furnish Letter of Undertaking (LUT).
• Select the financial year (e.g. 2026–27). The form lists three self-declarations — tick all three.
• Enter two independent witnesses: name, occupation, complete address.
• Select authorised signatory and sign with DSC (companies, LLPs) or EVC OTP (proprietors).
• Submit. The ARN appears immediately. Download the acknowledgement PDF and save the LUT number — you will quote it on every export invoice.

5. Validity, renewal and lapses

An LUT is valid for the financial year in which it is filed. File a fresh LUT at the start of every FY before raising the first export invoice. If you miss the renewal and continue to invoice, those supplies are taxable — you will have to pay IGST with interest under Section 50 CGST and claim a refund through the longer Section 54 route.

6. The Section 54 refund route — when it makes sense

If LUT eligibility is denied, or if your domestic ITC is very high and you want to monetise it, you can supply on payment of IGST and claim a refund under Section 54 CGST read with Rule 89. File RFD-01 with the standard documents — shipping bills are not required for services; FIRC/BRC and a CA-certified statement are. Refunds typically take 60–120 days.

7. GST return treatment

• GSTR-1: Table 6A — "Exports". Choose "Without payment of tax" for LUT supplies.
• GSTR-3B: Table 3.1(b) — "Outward taxable supplies (zero rated)". The IGST cell stays nil under LUT.
• Annual GSTR-9: zero-rated supplies aggregate in Table 4.

8. Practical FAQs — Upwork, Toptal, direct clients

• Direct client (e.g. US Inc paying via SWIFT): classic export — LUT, zero-rated, FIRC from your AD bank.
• Upwork / Toptal / Fiverr: the platform is your contractual counterparty, located outside India. Treat as export of services if the platform pays you from abroad in convertible FX and you have the platform's invoice/statement plus FIRC.
• Indian-resident customer of a foreign platform: If the end-user is in India and you are aware of it, the place of supply can shift. Get a CA view before assuming export treatment.

We file LUTs and handle the full export-of-services compliance cycle for freelancers and consultants. See our GST Export of Services — LUT service page, or set up the documentation framework for foreign payments with International Invoicing & Remittance Support.

Frequently Asked Questions