How to Apply for GST LUT for Export of Services (Form RFD-11)

Exporting services from India without paying Integrated GST upfront is possible through a Letter of Undertaking (LUT) filed under Form GST RFD-11. Every financial year, thousands of IT companies, freelancers, consultants, and service exporters file LUT on the GST portal to preserve working capital and avoid the IGST refund cycle. Filing LUT costs nothing, takes 1 to 3 working days for acceptance, and allows you to make zero-rated supplies throughout the financial year. This guide covers every aspect of the LUT process: eligibility, documents, step-by-step portal navigation, renewal, revocation, and the critical compliance obligations you must meet after filing.

What Is a Letter of Undertaking (LUT) Under GST?

Letter of Undertaking (LUT) is a self-declaration filed by a GST-registered exporter using Form RFD-11 on the GST portal, allowing the exporter to make zero-rated supplies of goods or services without paying Integrated GST at the time of supply. It is governed by Section 16(3) of the IGST Act, 2017 and Rule 96A of the CGST Rules, 2017.

Before the LUT simplification introduced through Circular No. 8/8/2017-GST dated October 4, 2017, exporters had to furnish a bond backed by a bank guarantee to export without IGST. The government replaced this requirement with a simple LUT for all eligible exporters, removing the financial burden of locking funds in bank guarantees. The current LUT framework was further clarified through Notification No. 37/2017-Central Tax dated October 4, 2017, which expanded LUT eligibility to all registered persons except those prosecuted for tax evasion exceeding Rs 2.5 crore.

The practical benefit of LUT is straightforward: without it, an exporter of services paying 18% IGST on a Rs 50 lakh export invoice would need to pay Rs 9 lakh upfront and then wait 30 to 60 days for a refund. With LUT, the same exporter pays Rs 0 in IGST and retains that Rs 9 lakh as working capital. For service exporters operating on thin margins or with multiple invoices per month, LUT is not optional; it is a business necessity.

Who Can File LUT Under GST: Eligibility Criteria

LUT eligibility under GST is intentionally broad. The government designed the framework to make LUT accessible to the maximum number of exporters, keeping the bond requirement only for a narrow category of disqualified persons.

Eligible Persons

Any person registered under GST who makes or intends to make zero-rated supplies can file LUT. This includes:

• IT and software companies exporting software development, SaaS products, or technology consulting services to overseas clients
• Freelancers and independent consultants providing services to clients located outside India (content writing, design, marketing, legal advisory)
• BPO, KPO, and outsourcing companies delivering back-office, data processing, or knowledge services to foreign entities
• Manufacturers and traders exporting physical goods from Indian ports
• Merchant exporters who purchase goods domestically and export them
• Suppliers to SEZ units or developers making supplies into Special Economic Zones
• Engineering and professional service firms providing architectural, engineering, or consulting services to foreign projects

Disqualified Persons (Must File Bond Instead)

Only one category of registered persons cannot file LUT: those who have been prosecuted under the CGST Act or IGST Act for any offence where the tax amount involved exceeds Rs 2.5 crore. Note that this refers to prosecution (criminal proceedings), not mere investigation or audit. A show cause notice, demand order, or pending appeal does not disqualify you from filing LUT. Only a formal prosecution initiated by the department triggers disqualification.

Understanding Zero-Rated Supply Under GST

Zero-rated supply under Section 16 of the IGST Act, 2017 means a supply of goods or services on which the GST rate is 0%, but the supplier retains full eligibility to claim input tax credit (ITC) on all inputs and input services used for making that supply. This is fundamentally different from an exempt supply, where GST is also 0% but no ITC can be claimed.

Two Categories of Zero-Rated Supply

Two Options for Making Zero-Rated Supplies

Under Section 16(3) of the IGST Act, a registered person making zero-rated supplies has two options:

1. Option 1: Export under LUT/Bond without paying IGST - File LUT (or bond), make the supply at 0% IGST, and claim a refund of accumulated ITC using Form GST RFD-01
2. Option 2: Export with IGST payment - Charge and pay IGST at the applicable rate on the export invoice, and claim a refund of the IGST paid. For goods, the refund is automatic via ICEGATE; for services, file Form GST RFD-01

Option 1 (LUT) is preferred by most exporters because it avoids the cash outflow of paying IGST upfront. For a service exporter with monthly billing of Rs 25 lakh, Option 2 would mean paying Rs 4.5 lakh in IGST every month and waiting 30 to 60 days for each refund. Over a full year, this locks up Rs 13.5 lakh to Rs 27 lakh in working capital at any given time.

LUT vs Bond Under GST: When Each Applies

Both LUT and bond serve the same purpose: enabling zero-rated supplies without IGST payment. The critical difference lies in cost, complexity, and who must use which option.

Documents Required for Filing LUT (Form RFD-11)

One of the biggest advantages of the LUT process is minimal documentation. Unlike the bond procedure that requires bank guarantees and physical submissions, LUT filing needs only digital documents and self-declarations.

Mandatory Documents

1. Active GSTIN - Your GST registration must be in active status. Suspended, cancelled, or surrendered registrations cannot file LUT
2. PAN card - PAN of the registered entity (company, LLP, proprietor, or partnership firm)
3. Self-declaration - Confirming that the applicant has not been prosecuted under CGST or IGST Act for tax evasion exceeding Rs 2.5 crore. This is a checkbox declaration within the online form
4. Witness details - Full name, residential address, and occupation of two independent and reliable witnesses. The witnesses do not need to be physically present or sign any document
5. Authorised signatory details - The signatory must be a working partner, managing director, compliance professional, proprietor, or a person authorised by the board of directors

Optional Documents

1. Previous year LUT copy - If renewing LUT for a new financial year, uploading the previous LUT helps demonstrate continuity. Accepted formats: PDF or JPEG, maximum 2 MB
2. Board resolution - Authorising a specific person to sign and file LUT on behalf of the company (required if the signatory is not a director or partner)

Step-by-Step Process to File LUT on the GST Portal

Filing LUT using Form RFD-11 is a straightforward online process that takes 15 to 20 minutes if you have all documents ready. Follow these 8 steps for a complete filing.

Step 1: Confirm Your Eligibility

Before starting the application, verify that your business meets the LUT eligibility criteria. Your GSTIN must be in active status (check under Services, then Registration, then View Registration on the GST portal). Confirm that your entity has not been prosecuted under the CGST or IGST Act for tax evasion exceeding Rs 2.5 crore. If you have received a show cause notice or demand order but no prosecution has been initiated, you remain eligible for LUT.

Step 2: Gather Required Information

Prepare the following before logging in: details of two independent witnesses (name, address, occupation), a scanned copy of your previous LUT (if renewing), and the name of your authorised signatory. Keep your DSC dongle connected to your computer or have your registered mobile phone ready for EVC verification.

Step 3: Log In to the GST Portal

Visit gst.gov.in and click the Login button. Enter your registered username (typically your GSTIN or a chosen username), password, and complete the CAPTCHA. After successful login, you land on your dashboard.

Step 4: Navigate to the LUT Application

From the top menu, click Services, then select User Services from the dropdown. Click Furnish Letter of Undertaking (LUT). The system opens Form GST RFD-11 pre-populated with your GSTIN, legal name, and trade name.

Step 5: Select Financial Year and Upload Previous LUT

Select the financial year for which you are filing the LUT from the dropdown (for example, 2025-26 for the period April 2025 to March 2026). If you are renewing, click Choose File to upload a scanned copy of your previous year's LUT in PDF or JPEG format (maximum 2 MB). First-time applicants skip the upload step.

Step 6: Enter Witness Details and Declarations

Fill in the details of two independent witnesses in the designated fields. For each witness, provide: full name, complete residential address, and occupation. Check both declaration checkboxes confirming that you meet the conditions for furnishing LUT and that you have not been prosecuted for the disqualifying offence. Enter the place of filing (typically your registered office city).

Step 7: Select Signatory, Sign, and File

From the authorised signatory dropdown, select the person who will sign the form. This must be a director, partner, proprietor, compliance professional, or an authorised representative. Click File with DSC to sign using your Digital Signature Certificate, or click File with EVC to receive a one-time password on your registered mobile number and email. Enter the OTP to complete filing.

Step 8: Download Acknowledgement and ARN

After successful submission, the GST portal generates an Application Reference Number (ARN) and displays a confirmation message. The ARN is also sent to your registered email and mobile number. Click Download to save the acknowledgement PDF. The LUT is typically accepted within 1 to 3 working days. Once accepted, you can start making zero-rated supplies without IGST payment.

Conditions You Must Meet After Filing LUT

Filing LUT is not a one-time action. You must continuously meet specific conditions throughout the financial year for your LUT to remain valid. Failure to comply triggers IGST liability with interest.

Export Completion Timelines

GSTR-1 and GSTR-3B Reporting

All zero-rated supplies made under LUT must be correctly reported in your GST returns. In GSTR-1, report export invoices under Table 6A (exports with payment of tax) or Table 6A (exports without payment of tax, which applies when you have a valid LUT). In GSTR-3B, report zero-rated supplies in Table 3.1(b) for supplies made without payment of tax. Incorrect classification in returns can delay your ITC refund processing.

Record-Keeping Obligations

Maintain complete records of all export transactions including: export invoices with recipient details, FIRC (Foreign Inward Remittance Certificate) or bank credit advice for each payment received, shipping bills for goods exports, and contracts or purchase orders from foreign clients. These records must be preserved for 72 months (6 years) from the due date of the annual return for the relevant financial year, as prescribed under Section 36 of the CGST Act.

How to Renew LUT for a New Financial Year

LUT is valid for one financial year only. Every year, before April 1, you must file a fresh LUT for the upcoming financial year. The renewal process is identical to the initial filing process described above.

Renewal Timeline

• Recommended - File the new LUT in the last week of March (between March 25 and March 31) for the upcoming financial year
• Deadline - There is no formal deadline, but you cannot export without IGST payment until the new LUT is accepted. Any export made between April 1 and the date of LUT acceptance will require IGST payment
• Grace period - The GST law does not provide any grace period. If your LUT lapses on March 31 and the new LUT is accepted on April 5, exports made on April 1 to April 4 are technically not covered

Renewal Checklist

1. Verify your GSTIN is active and all returns are filed up to date
2. Download and save a copy of the current year's LUT for upload
3. Confirm witness details are current (update if witnesses have moved or changed occupation)
4. Ensure your DSC is valid and not expired
5. File the new LUT under Services, then User Services, then Furnish LUT on the GST portal
6. Download the new acknowledgement and ARN

When LUT Gets Revoked: Causes and Consequences

The jurisdictional GST officer can revoke an accepted LUT if the exporter fails to meet the prescribed conditions. Revocation is a serious compliance event that immediately impacts your ability to export without IGST.

Grounds for LUT Revocation

1. Failure to export goods within 3 months - If goods mentioned in export invoices are not shipped within 3 months from the invoice date
2. Failure to receive payment for exported services - If foreign exchange payment is not received within the FEMA-prescribed timeline (9 months, extendable to 15 months)
3. Non-payment of IGST liability upon violation - If the exporter fails to pay the IGST and interest demanded after a condition violation
4. Prosecution initiated subsequently - If the exporter is prosecuted for tax evasion exceeding Rs 2.5 crore after filing LUT

Consequences of Revocation

Upon LUT revocation, the exporter must immediately:

• Stop making zero-rated supplies without IGST payment
• Pay IGST on all subsequent export supplies until a bond is furnished
• Furnish a bond with bank guarantee to the jurisdictional officer to continue exporting without IGST
• Pay the outstanding IGST liability with 18% interest for all supplies where conditions were violated

Claiming ITC Refund After Filing LUT

One of the primary financial benefits of LUT is the ability to claim a refund of accumulated Input Tax Credit (ITC). Since you do not pay IGST on exports, GST paid on domestic purchases (inputs, input services, and capital goods) accumulates as credit. This credit can be claimed as a cash refund.

ITC Refund Process

1. File Form GST RFD-01 on the GST portal under Services, then Refunds, then Application for Refund
2. Select refund type: Refund of ITC on account of exports without payment of tax
3. Enter the period for which you are claiming the refund
4. The system auto-calculates the refund amount using the formula in Rule 89(4) of CGST Rules: Refund = (Turnover of zero-rated supply / Adjusted total turnover) x Net ITC
5. Upload a Statement of Invoices (export invoices for which refund is claimed)
6. Submit with DSC or EVC

Refund Timeline

Five Conditions for Export of Services Under GST

For your supply to qualify as an export of services under GST and benefit from LUT, all five conditions specified in Section 2(6) of the IGST Act, 2017 must be satisfied simultaneously. Failing even one condition means the supply is not an export and IGST must be charged.

State-Wise Applicability and Special Cases

LUT under GST is a central government provision governed by the IGST Act and CGST Rules. It applies uniformly across all states and union territories. However, exporters operating from multiple states face specific compliance requirements that differ from single-state businesses.

Multiple GSTIN Scenario

If your business has GST registrations in multiple states (for example, a technology company with offices in Karnataka, Maharashtra, and Delhi), you must file a separate LUT for each GSTIN from which you make export supplies. A LUT filed under your Karnataka GSTIN does not cover exports invoiced from your Maharashtra registration. Each state registration is treated independently for LUT purposes. Plan your LUT filing schedule to ensure all GSTINs are covered before April 1 of each financial year.

SEZ Supplies vs Regular Exports

Both SEZ supplies and regular exports qualify as zero-rated supplies under Section 16 of the IGST Act. A single LUT covers both types. However, the documentation and endorsement requirements differ. For SEZ supplies, you need an endorsed Bill of Entry from the SEZ unit confirming receipt of goods or services. For regular exports of goods, you need a shipping bill filed with Customs. For export of services, the key documentation is the FIRC confirming receipt of foreign exchange payment.

Deemed Exports Are Not Covered by LUT

Deemed exports under Section 147 of the CGST Act are fundamentally different from zero-rated supplies. Supplies to Export Oriented Units (EOUs), supplies against Advance Authorisation, and supplies to projects funded by multilateral agencies qualify as deemed exports. These supplies attract normal GST (not zero-rated), and the recipient claims a refund. LUT does not apply to deemed exports. If you supply to an EOU, charge GST at the normal rate and the EOU claims a refund.

LUT for E-commerce and Digital Service Exports

The rise of cross-border digital services has created a significant category of service exporters who use LUT. Indian businesses selling digital products, SaaS subscriptions, and online services to foreign customers need to understand how LUT interacts with e-commerce payment structures.

Payment Through International Gateways

Many service exporters receive payments through platforms like PayPal, Stripe, Wise (formerly TransferWise), or Payoneer. For LUT purposes, the critical requirement is that the payment must be received in convertible foreign exchange. When PayPal or Stripe settles your payment in INR after converting from the foreign currency, the transaction still qualifies as foreign exchange receipt, provided the underlying payment was made in foreign currency by the overseas client. Maintain bank statements and PayPal/Stripe settlement reports as proof of foreign exchange receipt.

Marketplace-Based Exports

If you sell software, templates, or digital products through international marketplaces (Envato, Gumroad, App Store, Google Play), the marketplace typically collects payment from the end customer and remits your share. The marketplace's payment to you is the export consideration. Ensure the marketplace settlement is documented as foreign exchange receipt. For app developers, monthly settlements from Apple or Google serve as the FIRC equivalent. Keep all settlement statements organised by financial year for GSTR-1 reconciliation.

Subscription-Based SaaS Exports

SaaS companies invoicing monthly or annual subscriptions to foreign clients should issue export invoices for each billing cycle. Each invoice is a separate zero-rated supply under LUT. For annual subscriptions paid upfront, the entire amount is a single zero-rated supply at the invoice date. Track the FEMA payment timeline from each invoice date individually. A SaaS company with 50 international clients issuing monthly invoices generates 600 export invoices per year, all of which must be reported in GSTR-1 Table 6A.

Comparison: LUT Filing vs IGST Refund Route

Understanding the financial impact of choosing LUT over the IGST refund route helps exporters make an informed decision. While both routes achieve the same end result (zero effective tax on exports), the cash flow implications are dramatically different.

For a service exporter billing Rs 50 lakh per quarter to overseas clients, the LUT route saves approximately Rs 4.5 lakh in IGST cash outflow per quarter. Over a full financial year, this translates to Rs 18 lakh in working capital that remains available for business operations instead of being locked in IGST refund cycles. For startups and small businesses where cash flow is critical, LUT is the clear winner.

Common Mistakes When Filing LUT and How to Avoid Them

While the LUT filing process is simple, exporters frequently make errors that lead to compliance issues, delayed refunds, or inadvertent IGST liability. Here are the most common mistakes and their solutions.

Mistake 1: Not Filing LUT Before Starting Exports

New exporters sometimes start exporting services first and then file LUT, assuming it can be applied retroactively. LUT is prospective, not retrospective. Supplies made before LUT acceptance are not covered. Always file and get LUT accepted before issuing your first export invoice for the financial year.

Mistake 2: Forgetting to Renew Before April 1

This is the single most common mistake. Exporters who filed LUT in the previous year assume it carries over automatically. It does not. A fresh LUT must be filed for each financial year. Set a March 20 calendar reminder and file before the year-end rush.

Mistake 3: Incorrect Invoice Classification in GSTR-1

Export invoices must be reported in Table 6A of GSTR-1 with the correct flag: "Without Payment of Tax" for supplies under LUT. If you accidentally select "With Payment of Tax," the system expects you to have paid IGST, creating a mismatch that delays ITC refund processing. Always double-check the IGST flag before filing GSTR-1.

Mistake 4: Not Tracking Payment Receipt Timelines

For service exports, the FEMA timeline for receiving payment is 9 months from the invoice date. If payment is not received within this period and you have not obtained an RBI extension, IGST plus 18% interest becomes payable. Maintain a spreadsheet or use accounting software that flags invoices approaching the 9-month mark.

Mistake 5: Using Ineligible Persons as Signatories

The authorised signatory for LUT must be a working partner, managing director, compliance professional, proprietor, or a person specifically authorised by the board. An accountant, office manager, or consultant without formal board authorisation cannot sign the LUT. Ensure the signatory is properly registered on the GST portal under the authorised signatory list.

LUT for Specific Business Types

Different types of businesses have different practical considerations when filing and using LUT for export services. Here is a breakdown by business type.

IT and Software Companies

Indian IT companies are the largest users of LUT. Whether you provide custom software development, SaaS products, managed IT services, or technology consulting, LUT is essential for cash flow management. Ensure your service agreements clearly specify that the recipient is located outside India and that payment is received in foreign exchange. For SaaS companies receiving payments via Stripe, PayPal, or Razorpay International, confirm that the payment settlement happens in convertible foreign exchange to satisfy the export condition.

Freelancers and Sole Proprietors

Individual freelancers registered under GST can file LUT. If your annual turnover from export services exceeds Rs 20 lakh (the GST registration threshold for services), you must register for GST and then file LUT. Many freelancers on platforms like Upwork, Fiverr, and Toptal use LUT to export services without IGST. The filing process is identical; the only difference is that the proprietor is both the applicant and the authorised signatory.

Startups and Small Businesses

If you are a startup providing services to international clients, file LUT immediately after obtaining your GST registration. Do not wait until you have accumulated significant export revenue. LUT is free to file and valid for the entire financial year. Even if you export only one service in the year, having LUT in place protects you from IGST liability on that transaction.

GST LUT Cost in 2026

Filing LUT under GST is one of the few compliance processes in India that is entirely free from the government side. Here is the complete cost breakdown.

Compare this with the bond option, where the bank guarantee fee alone costs 1% to 3% of the guaranteed amount annually. For an exporter with Rs 1 crore in annual exports, a bond with 15% bank guarantee would cost Rs 15,000 to Rs 45,000 per year in bank charges. LUT eliminates this cost entirely.

Export of Services: FEMA Compliance and Payment Timelines

Filing LUT handles the GST side of export compliance, but service exporters must also comply with the Foreign Exchange Management Act (FEMA), 1999 regarding payment receipt. FEMA compliance is monitored by the Reserve Bank of India (RBI) and affects your LUT validity.

Payment Receipt Timelines Under FEMA

Impact on LUT

If payment for exported services is not received within the FEMA timeline, two things happen simultaneously: the RBI may flag the non-receipt, and the GST department considers the LUT condition violated. You must then pay IGST at 18% (for most services) along with interest at 18% per annum from the invoice date to the date of actual payment. This dual compliance requirement makes payment tracking absolutely critical for service exporters.

LUT and GST Annual Return: Reconciliation

All exports made under LUT during the financial year must be reconciled in your GST Annual Return (GSTR-9) and, where applicable, the Reconciliation Statement (GSTR-9C). Proper reconciliation ensures that your export data across GSTR-1 (monthly/quarterly), GSTR-3B (summary), and GSTR-9 (annual) matches perfectly.

Key Reconciliation Points

• Table 6A of GSTR-1 - Total export invoices (without IGST) must match the GSTR-9 annual totals
• Table 3.1(b) of GSTR-3B - Zero-rated supplies without payment of tax must match GSTR-1 data
• GSTR-9 Table 4 - Verify that the total zero-rated supply figure matches your books of accounts
• GSTR-9C - If applicable (turnover above Rs 5 crore), the auditor will verify export turnover against FIRC/bank certificates
• ITC refund claims - Ensure all ITC refunds claimed via RFD-01 during the year are reflected correctly in the annual return

Frequently Encountered Issues and Resolutions

Issue 1: GST Portal Shows "LUT Already Filed for This FY"

This error appears when a LUT has already been filed and accepted for the selected financial year. You cannot file a second LUT for the same FY. If you need to update witness details or correct information, you must contact your jurisdictional GST officer directly. The portal does not allow amendments to an accepted LUT.

Issue 2: DSC Validation Failure During Signing

DSC errors typically occur when: the DSC has expired (check validity dates), the DSC is not registered on the GST portal (register under My Profile, then Register/Update DSC), or the Java/emSigner utility is not installed or updated. Install the latest version of the emSigner tool from the GST portal's download section and restart your browser before attempting to sign again.

Issue 3: ARN Generated But LUT Not Accepted for Weeks

If your LUT shows "Submitted" status for more than 7 working days without moving to "Accepted," the jurisdictional officer may have raised an internal query. Contact your jurisdictional GST officer's office with your ARN number. In most cases, the delay is due to administrative backlog, and a follow-up resolves it within 2 to 3 days.

Issue 4: Exporter Made Supplies Before LUT Acceptance

If you issued export invoices before LUT acceptance (for example, on April 1 when LUT was filed on April 3 and accepted on April 5), technically those supplies are not covered by LUT. The safest approach is to report those specific invoices as exports with IGST payment, pay the IGST, and claim a refund. Once LUT is accepted, subsequent invoices are covered.

Penalties, Interest, and Compliance Risks for LUT Holders

While LUT itself has no government fee, violations of LUT conditions carry significant financial consequences. Understanding the penalty structure helps exporters maintain strict compliance and avoid unnecessary costs.

Interest on Delayed Export Completion

If goods are not exported within 3 months from the invoice date or service export payment is not received within the FEMA-prescribed 9-month window, the exporter must pay IGST at the applicable rate along with interest at 18% per annum under Section 50 of the CGST Act. The interest is calculated from the date of the original invoice until the date of actual IGST payment. For a service exporter with an outstanding invoice of Rs 25 lakh where IGST payment is delayed by 6 months beyond the deadline, the interest alone amounts to approximately Rs 2.25 lakh (18% of Rs 4.5 lakh IGST for 6 months). This makes payment tracking a non-negotiable compliance activity for every LUT holder.

Penalty for Incorrect GSTR-1 Reporting

If export invoices are incorrectly classified in GSTR-1 (for example, reporting exports without IGST as exports with IGST, or vice versa), the GST officer can issue a notice under Section 73 of the CGST Act for short payment of tax. The penalty for genuine errors is typically 10% of the tax due or Rs 10,000, whichever is higher. For deliberate misreporting, the penalty under Section 74 can go up to 100% of the tax due. Always verify the IGST flag in Table 6A before filing each month's GSTR-1.

Late Filing of ITC Refund Claims

ITC refund applications under Form GST RFD-01 must be filed within 2 years from the relevant date as defined in the Explanation to Section 54 of the CGST Act. For exports without payment of tax (LUT route), the relevant date is the end of the financial year in which the export was made. Missing this deadline means you permanently lose the ability to claim the ITC refund for that period. A service exporter with Rs 5 lakh in accumulated ITC who misses the 2-year deadline loses that entire amount. File refund claims quarterly or at least biannually to avoid this risk.

Annual Compliance Calendar for LUT Holders

Related Services and Resources

• GST LUT Filing Service - Professional assistance for filing and renewing LUT on the GST portal
• GST Registration - Get your GSTIN before filing LUT, required for all exporters
• GST Return Filing - Monthly GSTR-1 and GSTR-3B filing with correct export classification
• Import Export Code (IEC) Registration - Required for businesses involved in import and export of goods
• GST E-Invoicing - Mandatory for businesses with turnover above Rs 5 crore, including exporters
• GST Notice Reply - Expert assistance if you receive a notice related to LUT or export compliance

Summary

Filing a Letter of Undertaking (LUT) under GST using Form RFD-11 is a free, fully online process that every service exporter in India should complete before making zero-rated supplies. The process takes 15 to 20 minutes, costs nothing, and the acceptance typically arrives within 1 to 3 working days. LUT must be renewed annually before April 1. The eligibility criteria are broad, covering all GST-registered exporters except those prosecuted for tax evasion exceeding Rs 2.5 crore.

After filing LUT, track payment receipt timelines rigorously to stay within the FEMA-prescribed 9-month window for service exports. Report all export invoices correctly in GSTR-1 Table 6A with the "Without Payment of Tax" flag, and reconcile with GSTR-3B Table 3.1(b) every month. File ITC refund claims using Form GST RFD-01 quarterly to recover accumulated input tax credit and maintain healthy cash flow. Maintain complete documentation, including export invoices, contracts, FIRCs, and bank credit advices, for a minimum of 6 years as prescribed under Section 36 of the CGST Act.

For companies with multiple state registrations, file a separate LUT for each GSTIN. For SaaS companies and digital service exporters receiving payments through PayPal, Stripe, or other international gateways, maintain settlement reports as proof of foreign exchange receipt. LUT is the most cash-flow-efficient method for making zero-rated supplies, saving exporters from blocking working capital in IGST refund cycles.

For professional assistance with LUT filing and export GST compliance, our team of Tax Professionals and GST practitioners can handle the entire process for you.