Invoicing UK Clients From India: UK VAT, the Reverse Charge and the Pound Invoice

A London agency wants to hire you. Their accounts team sends a supplier form that asks for your "VAT number". You don't have one. You have a GSTIN. Is that a problem?

Usually not. When you are invoicing UK clients from India, the UK VAT question has a short answer for business clients and a narrower one for consumers. Everything else is the same export invoice you'd send a US client, just in pounds. This post covers both sides: what HMRC expects, and what Indian GST and FEMA still expect from you.

Not legal or tax advice. A plain explainer for Indian freelancers billing UK clients, based on HMRC's published guidance and the Indian rules as they stand on 2 November 2026. Check anything unusual with a CA, and with a UK VAT adviser for the UK side.

If you've read our guide to invoicing EU clients, the shape will look familiar. But the UK left the EU, and its VAT rules are now its own. The EU Directive, VIES and the One Stop Shop don't apply to a UK client.

Invoicing UK clients from India: the short version

• UK business client: you don't charge UK VAT. The client deals with it under the reverse charge.
• UK consumer: most services you perform yourself are taxed where you belong, so no UK VAT either. Automated digital services sold to UK consumers are the exception, and there's no registration threshold for you.
• On the Indian side: it's an export of services. With an LUT, no IGST, and the export endorsement goes on the invoice.
• Bill in GBP. Record the INR value for your books and your GST return.
• FEMA clocks start on the invoice date: nine months to realise the money, and a monthly EDF.

Why you don't charge VAT to a UK business

HMRC's guidance on where services are taxed is VAT Notice 741A. Its two general rules are short:

• Section 6.3: "The B2B general rule for supplies of services is that the supply is made where the customer belongs."
• Section 6.2: "The general rule for B2C supplies of services is that the place of supply is where the supplier belongs."

So when you build a website for a company in Manchester, the supply is made in the UK. But you're not in the UK. The notice moves the VAT to the customer. For a non-UK supplier and a UK VAT-registered customer, section 13.5 says "it's you, the customer that accounts for the VAT using the reverse charge procedure."

In practice, the customer acts as if they had both supplied and received your service (section 5.1). They record UK VAT on your fee in their own VAT return and, for most businesses, reclaim it in the same return. GOV.UK's own summary for UK buyers: "there will be no tax for you to pay, unless your business is partially exempt from paying VAT".

No money moves to you or from you. Your invoice shows no VAT line.

Don't print a UK VAT registration you don't have. HMRC's notice (section 5.17) tells UK customers that if a non-UK supplier's invoice shows UK VAT, the reverse charge still applies, and they "should advise your supplier to amend or correct their invoice". In other words, it comes back to you.

How do you know the client is a business?

This matters because the business rule and the consumer rule point in opposite directions.

HMRC makes it easy. Section 2.4 of Notice 741A: "you may presume that your customer is in business if they provide you with their VAT number." UK VAT numbers begin with GB. You can confirm one is live on HMRC's free "Check a UK VAT number" service before you send the first invoice.

Many small UK businesses are not VAT-registered. If the client has no VAT number, section 6.3 says you "can accept alternative evidence", such as "certificates from fiscal authorities or other commercial documents". A Companies House registration, a signed contract in the company's name and their business address are the practical version. Keep whatever you rely on with your records.

What an unregistered UK client does next is their business, not yours. HMRC tells them (section 5.7) that services bought from abroad under the general rule are added to their own taxable supplies when they check whether they must register. You still invoice without VAT.

What to put on the invoice for a UK business

UK invoice rules are written for UK VAT-registered businesses. HMRC's place-of-supply notice doesn't give a non-UK supplier a list of fields. Your client's accountant still has to justify the reverse charge in their books, though, so three things help:

1. 1.The client's VAT number, if they have one, with their full UK address.
2. 2.A specific description of the work. Section 2.3 asks that invoices "avoid general or generic descriptions and make clear the nature of the services involved." "Design and build of marketing website, October 2026" beats "Professional services".
3. 3.A reverse charge note. Not required of you by UK law, but most UK accounts teams look for it. A line such as "Reverse charge: customer to account for UK VAT" costs nothing.

None of this replaces anything Indian GST requires. It all sits alongside it.

What about UK consumers?

Most Indian freelancers bill businesses. But if you coach individuals, edit a memoir for a retired teacher in Leeds or design a wedding site for a couple in Bristol, your client is a consumer.

For services you perform yourself, the B2C general rule applies: the place of supply is where the supplier belongs. That's India. No UK VAT.

The exception is electronically supplied services: a SaaS subscription, a paid template library, a self-serve online course. Section 14 of the notice says that for these, "your place of supply will be where the consumer is located." GOV.UK's list of services with different rules gives examples such as web hosting and music downloads, where there's no one directly involved.

This is where the UK is stricter than you might expect. Section 2.6: "If you are not established in the UK, there is no registration threshold for taxable supplies of services." The UK's familiar £90,000 threshold is for UK businesses. If you sell an automated digital product to UK consumers, you may need to register for UK VAT from the first sale. Speak to a UK VAT adviser before you launch, not after.

The Indian side: it's still an export

UK VAT tells you not to charge VAT. Indian GST asks a separate question: is this an export of services? For a typical UK business client, paying from abroad, for work you do in India, yes. The five conditions are in our USD invoicing guide, and they don't change because the currency is pounds.

As an export, it's zero-rated. You have two choices:

• With an LUT on file: no IGST. The invoice carries the export endorsement. Rule 46 of the CGST Rules gives it as "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". On a service export under LUT, the part that applies reads: supply meant for export under letter of undertaking without payment of integrated tax.
• Without an LUT: you charge IGST, pay it, and claim a refund. For a freelancer, that's months of your money sitting with the government.

If you haven't filed this year's LUT, here's how to file Form GST RFD-11. It's free, and you file it once a financial year.

Rule 46 also asks export invoices for the "name and address of the recipient", the "address of delivery" and the "name of the country of destination". Put the client's full UK address on the invoice and write "United Kingdom" in full.

So an export invoice to a UK business carries two "no tax here" lines from two different systems:

• The reverse charge note, for the client's UK VAT return.
• The LUT endorsement, for your Indian GST return.

They don't conflict. Each is for a different tax authority.

Pounds on the invoice, rupees in your books

Bill in GBP. Your client expects it, and it avoids a conversion argument later. But your GST return and your books are in INR, so each pound invoice needs a rupee value as well.

That rupee value comes from the exchange rate for the invoice date, not the rate your bank gives you when the money lands. The two will differ, and the difference is a foreign exchange gain or loss. Pick one source for the invoice-date rate with your CA and use it for every invoice.

One more reason to bill in pounds rather than rupees: the FEMA realisation period depends on it. Nine months for a foreign-currency invoice, twelve if it's invoiced or settled in INR.

Worked example: a Mumbai developer and a London agency

Arjun is a freelance developer in Mumbai. He is GST-registered and filed his LUT for FY 2026-27 in April. On 2 November 2026 he invoices Fenwick & Hale Ltd, a design agency in London, for building the front end of a client site. Fenwick & Hale is VAT-registered.

What happens next:

• Fenwick & Hale records UK VAT on £2,400 in its own return under the reverse charge. Arjun never sees that number.
• Arjun reports the invoice in GSTR-1 as a zero-rated export, at the rupee value.
• The EDF clock. Under the FEMA (Export and Import of Goods and Services) Regulations, 2026, Regulation 3(2), an exporter of services files an EDF "within 30 days from the end of month in which invoice for services has been raised". For a November invoice, that's 30 December 2026, and one EDF can cover all of November's invoices. Code is a "computer programme", which Regulation 2(1)(e) counts as software, so Arjun can't wait and file on the date of payment the way some non-software exporters can.
• The realisation clock. Regulation 5, as amended from 1 October 2026, gives "nine months from... the date of invoice in case of services". That's 2 August 2027. If Fenwick & Hale pays on 2 December, this is irrelevant. If it pays late, this is the date to watch.
• The LUT clock. Under Rule 96A(1)(b), the LUT's promise runs to "fifteen days after the expiry of one year, or the period as allowed under the Foreign Exchange Management Act... whichever is later". Here, one year plus fifteen days is later: 17 November 2027. If the money still hasn't arrived by then, IGST with interest becomes payable.

Five mistakes that get UK invoices sent back

1. 1.Adding UK VAT. You aren't registered for it, and the client's accountant will ask for a corrected invoice.
2. 2.Treating the UK as the EU. No VIES check, no EU VAT number, no Article 196 line. Use HMRC's checker and a plain reverse charge note.
3. 3.A vague description. "Consulting services" invites questions. Say what you did and for which period.
4. 4.Writing "GST 0%" with no endorsement. Indian rules ask for the export endorsement on the invoice. Print it.
5. 5.Invoicing in INR to "keep it simple". Bill in GBP. Keep the rupee figure for your own records and return.

Keeping it right every month

The UK part is simple once it's set up: one client VAT number, one reverse charge line. The harder part is month after month: the endorsement, a rupee value for every pound invoice, and knowing which invoices are still unpaid as the nine-month clock runs.

Mavoin makes export and GST invoices from one account, and tracks paid and outstanding amounts in INR, with a CSV export of your invoices when your CA asks. It's ₹199/month, with a 30-day trial and no card to start. If you only need one invoice today, the free export invoice generator opens in pounds with the LUT endorsement in place.

Mavoin is not a Chartered Accountant service. Verify GST, FEMA and UK VAT specifics with your CA and, for UK VAT, an adviser in the UK.