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

If you invoice foreign clients from India, the Letter of Undertaking decides whether your export invoices carry tax. With an LUT on file, you bill your US or EU client with no IGST line. Without one, you charge IGST, pay it, and chase a refund for months.

It takes about fifteen minutes on the GST portal and costs nothing — yet half the freelancers who need one still haven't filed it.

Not legal advice. Confirm your specifics with a CA — especially if you've already exported this financial year without an LUT in place.

What an LUT actually is

Export of services is a zero-rated supply under Section 16 of the IGST Act. Zero-rated means 0% tax with your input tax credit intact — not exempt, which would cost you the credit.

But zero-rating isn't automatic. The law gives you two doors:

• Export under LUT — you undertake, in writing, to meet the export conditions. No tax charged, nothing paid, nothing to reclaim.
• Export on payment of IGST — you charge and pay the tax, then file for a refund.

The LUT is that written undertaking, submitted as Form GST RFD-11. For a solo business, door one is almost always right — door two means lending the government your working capital while you wait.

Still working out whether your work qualifies as an export? Our guide to invoicing foreign clients in USD covers the five conditions.

Who can file one

Effectively every GST-registered exporter. Notification 37/2017 extended the LUT facility broadly, with one exclusion: anyone prosecuted for tax evasion above ₹2.5 crore under the CGST or IGST Act (or an earlier law). They must furnish a bond with a bank guarantee instead.

For a freelancer or small studio, this exclusion isn't your problem — you're eligible.

You do need to be GST-registered first. Not sure? See do freelancers need GST registration.

Before you start: three things to have ready

1. Portal access. Your GSTIN login, plus either a registered DSC or a phone for OTP-based EVC. A sole proprietor can use EVC; companies and LLPs generally need the DSC.

2. Two witnesses. The form requires the name, address, and occupation of two independent witnesses. This surprises people. Any two who aren't you — a friend, neighbour, or colleague — will do; have their details ready before you open the form.

3. Last year's LUT, if you have one. Not required, but useful for reference.

The steps

1. 1.Log in at gst.gov.in.
2. 2.Go to Services → User Services → Furnish Letter of Undertaking (LUT).
3. 3.Select the financial year from the dropdown. This is where most mistakes happen — check it twice.
4. 4.If you filed an LUT for a previous year manually, upload it. Most people skip this.
5. 5.Tick the three self-declaration checkboxes. These are the undertakings themselves: complete the export within the prescribed time, abide by GST law, and pay IGST with interest if you fail to.
6. 6.Enter the two witnesses' names, occupations, and addresses.
7. 7.Enter place of filing and the authorised signatory's name.
8. 8.Sign and file with DSC or EVC.
9. 9.An ARN is generated. Download the acknowledgement PDF.

That's it — no officer approval, no waiting period. Since Circular 40/2018 the LUT is deemed accepted once the ARN is generated, so you can raise a zero-rated export invoice the same day. Save the acknowledgement PDF — the ARN belongs on your export invoices.

The renewal trap

An LUT is valid for one financial year only.

It expires on 31 March and does not roll over. No reminder email, no portal banner — nothing stops you from raising invoices without one. You keep billing and discover in the third quarter that every invoice since April was issued against an expired undertaking.

Filing opens the preceding February or March, so you can have it in place before 1 April. Two habits worth building:

• A recurring calendar entry for the first week of April, titled with the form name so future-you knows what it means.
• The LUT ARN and date printed on every export invoice. Not mandatory under Rule 46, but then the invoice itself shows whether it was covered.

What goes on the invoice once it's filed

Filing the LUT is half of it. The invoice has to reflect it. Under Rule 46, an export invoice must carry this endorsement, printed clearly:

SUPPLY MEANT FOR EXPORT UNDER LUT WITHOUT PAYMENT OF INTEGRATED TAX

No CGST, SGST, or IGST lines with values. Place of supply is the client's country; state the country of destination. Everything else a domestic tax invoice needs still applies — GSTIN, SAC code, unbroken invoice series. The GST invoice format guide has the full field list.

Then, after you send it:

• Report the invoice in GSTR-1, Table 6A.
• Receive payment in convertible foreign exchange within one year of the invoice date. Past twelve months, the export stops qualifying and the tax becomes payable with interest — one of the boxes you ticked. Chase anything approaching nine months.
• Keep the FIRC or FIRA your bank issues for each incoming payment.

What if you've already exported without one?

It happens constantly — someone bills their first foreign client in May, files the LUT in September when their CA asks, and wonders about the invoices in between.

The honest answer depends on your specific facts — exactly the conversation to have with a CA, not a blog post. The options generally involve either paying the IGST and claiming a refund, or making the case for regularisation. What you should not do is file the LUT and assume it covers the past.

File it now regardless. Every day without one adds to the problem.

Getting the endorsement right, every time

The filing is annual and manageable. The invoice discipline is monthly and easy to slip — a missing endorsement line, a mistyped SAC code, an FX rate looked up by hand.

Mavoin handles it as a setting, not a memory test. Toggle your LUT on once and foreign invoices come out zero-rated with the correct endorsement; domestic invoices get the right CGST/SGST or IGST split, FX captured on the invoice date, INR kept in your books.

At ₹199/month, with a 30-day trial and no card to start, you can start your 30-day trial and put the endorsement on autopilot — simple invoices for people who run businesses, not books.

Mavoin is not a Chartered Accountant service. Verify GST specifics with your CA.