Export Invoice Under LUT for Indian Freelance Developers
By Mark Fulton · · 11 min read
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If you are a developer in India billing a client abroad, the invoice you send is not a normal domestic GST invoice with the tax line deleted. It carries a specific sentence, the client's foreign address and country, and a reference to a Letter of Undertaking you filed beforehand.
An export invoice under LUT is a GST tax invoice for services you supply to a client outside India, issued without charging IGST because you have furnished a Letter of Undertaking (LUT). The invoice must carry the endorsement the GST rules prescribe for exports under a bond or LUT, show the client's name, address and country instead of a state, and state the amounts in the currency you agreed with the client. You file the LUT on the GST portal before you invoice, and it covers one financial year at a time. After that, the invoice itself is mostly the same document you already send. The real work is the paperwork behind it: proof that the money arrived from abroad.
Everything below is general information for developers, not tax or legal advice. GST rules change by notification, and your own facts (registration status, client structure, how you are paid) can change the answer. Confirm the details with a chartered accountant before you file anything or send your first export invoice. The rule references in this article were checked against CBIC's published rule text and circulars on 19 October 2026, and I link each one so your accountant can read the same page.
When is a developer's foreign invoice an export of services?
Short version: you are in India, the client is outside India, the work is a service (software development, maintenance, consulting), and you get paid in convertible foreign exchange.
The legal test sits in the definition of "export of services" in the IGST Act, which lists a handful of cumulative conditions: the supplier is located in India, the recipient is outside India, the place of supply is outside India, payment arrives in convertible foreign exchange (or in rupees where the RBI allows it), and the two parties are not just branches of the same legal person. Read the definition on the CBIC site yourself and have your accountant confirm each condition against your situation, because one failed condition turns a zero-rated export into a taxable domestic supply.
Two checks catch most mistakes before they reach an invoice:
- Is the client really outside India? An Indian subsidiary of a US company is a different case from the US company itself. If your contract is with an Indian entity, this article does not apply to that invoice.
- How does the money arrive? CBIC's own circulars tie service exports to receipt of payment in convertible foreign exchange. circular 8/8/2017-GST says, in the context of Nepal and Bhutan, that supply of services there is deemed an export of services only if the payment is received in convertible foreign exchange. For ordinary foreign clients, the same expectation is why your payment trail matters later in this article.
The Ministry's circular 8/8/2017-GST also notes that export contracts and invoices may be denominated either in freely convertible currency or in Indian rupees, while export proceeds are realized in freely convertible currency. So invoicing in rupees to a foreign client is not forbidden, but you still need the foreign-currency receipt.
What is an LUT and when do you file it?
An LUT is a declaration you furnish to the tax department, in FORM GST RFD-11, saying you will export without paying IGST and will pay the tax with interest if you fail to meet the export conditions. The alternative is to pay IGST on every export invoice and claim it back as a refund. The LUT route keeps your cash out of that refund queue.
What CBIC's circular 8/8/2017-GST says about it:
- Who qualifies: every registered person who intends to supply goods or services for export without paying integrated tax, except people who have been prosecuted for an offence under the GST laws where the tax evaded exceeds two hundred and fifty lakh rupees. A self-declaration that you have not been prosecuted is what the circular says should suffice.
- How long it lasts: the LUT is valid for the whole financial year in which it is tendered. That means one per financial year, filed again for each new April-to-March year.
- When to file: before you effect the zero-rated supply. Circular 37/11/2018-GST describes the LUT as something an exporter furnishes before effecting zero-rated supplies.
- If you forgot: the same 2018 circular says the substantive benefit of zero rating may not be denied where exports are established, and that a delay in furnishing the LUT may be condoned and the facility allowed on an ex post facto basis, depending on the facts of each case. Do not plan around that. Treat it as a rescue, ask your accountant, and file the LUT first next time.
Registration matters here: the circular speaks of registered persons. If you are not GST-registered, ask your accountant whether you need to be before your first export invoice. Do not guess at thresholds from a blog post, including this one.
Filing itself happens on the GST portal. The portal's own user guide for furnishing a Letter of Undertaking is the place to follow the click path, because the portal screens change more often than articles do. Keep the acknowledgment and the LUT reference number. You will print them on invoices.
What must an export invoice under LUT show?
Rule 46 of the CGST Rules lists what a tax invoice contains. For exports, a proviso adds two things: an endorsement, and a replacement for the recipient details.
The endorsement reads, in the rule's wording: "SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX". The version for exports that pay IGST ends "ON PAYMENT OF INTEGRATED TAX" instead. Copy the sentence as the rule words it. Short paraphrases such as "Export under LUT" appear on plenty of templates, but the full sentence is the one that matches the text, and it costs you one line.
In place of the usual recipient details for an unregistered buyer, the proviso asks for three things: the recipient's name and address, the address of delivery, and the name of the country of destination.
The rest of rule 46 still applies to you as a registered supplier. That includes your name, address and GSTIN; a consecutive serial number of up to sixteen characters, unique for the financial year; the date of issue; the code for the service; a description; the value of supply and the taxable value after any discount; the rate and amount of tax; and a signature or digital signature. The rate and amount are zero for a supply under LUT, but show them as zero rather than removing the rows. If you want a fuller list of what a dev invoice carries beyond the legal minimum, what belongs on a software development invoice covers it.
What does the annotated invoice look like?
Here is a text version of a services export invoice. The numbers in brackets are the call-outs explained underneath.
[1] TAX INVOICE
Invoice No. 2026-27/014 Date 19 Oct 2026
[2] Supplier Asha Rao (Freelance Software Development)
12 Lake Road, Pune, Maharashtra, India
GSTIN 27XXXXX1234X1Z5 | LUT ARN: <your LUT reference>, FY 2026-27
[3] Bill to Northwind Labs Inc.
500 Example Street, Austin, TX, United States
Country of destination: United States
Delivery / place of supply: Outside India
SAC Description Qty Rate (USD) Amount (USD)
[4] <SAC> API integration, sprint 6 (22 Sep-3 Oct) 1 4,800.00 4,800.00
<SAC> Staging environment hosting setup 1 600.00 600.00
Taxable value USD 5,400.00
[5] IGST @ 0% (export under LUT) USD 0.00
Total USD 5,400.00
[6] Exchange rate used for INR records: <rate and source> = INR <amount>
[7] SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING
WITHOUT PAYMENT OF INTEGRATED TAX
Payment: SWIFT/bank transfer in USD to <account>. Please reference the invoice number.
Signature: ______________________
The call-outs:
- Invoice number. Sequential and unique within the financial year, sixteen characters or fewer. A year-prefixed scheme like the one in invoice numbering for freelancers fits.
- Your identity and LUT reference. GSTIN, plus the LUT reference and its financial year, so a reviewer sees which undertaking you are relying on.
- Client block. Full legal name, full foreign address, country of destination. This replaces the state and state-code line you would use for a domestic customer.
- Service code and description. A real description tied to the work, not "development services". Your accountant will tell you the code that fits your work; verify it rather than copying one from a template.
- Zero tax line. Keep the row, show zero, and label why.
- Rupee equivalent. Your books are in rupees, so record the conversion and where the rate came from. See the next section.
- The endorsement sentence. Placed where nobody can miss it, usually directly under the totals.
Which currency and exchange rate go on the invoice?
Bill in the currency you agreed with the client. USD and EUR are normal, and the CBIC circular quoted above says export contracts and invoices can be in convertible currency or in rupees. Invoicing in the client's currency means the client pays the amount in the contract, with your bank taking the conversion on receipt.
Two practical rules keep this clean:
- Show the foreign amount as the legal amount, and the rupee value as a labeled line. The invoice is for USD 5,400. The INR line says how you valued it.
- Record the rate and the source on the day you issue the invoice. I am not going to tell you which official rate GST requires here, because I could not verify that on an official page this run. Ask your accountant which source and which date they want, then write the same source on every invoice. A consistent rule beats a clever one.
When the money lands, the bank credit will be in rupees at the bank's own rate. The difference between your invoice-date rupee value and the credited amount is a forex difference for your books. It is not a reason to reissue the invoice.
If you want to invoice in USD but your template is built for rupees, billable.dev lets you set the currency and relabel the tax line yourself. Put "IGST @ 0% (export under LUT)" in the tax label and the endorsement sentence in the notes. Fuller multi-currency habits are in how to invoice international clients as a developer.
What records show the payment came from abroad?
The law ties the export of services to realization of payment. CBIC's circular 37/11/2018-GST says that under rule 96A, if payment for services is not received in convertible foreign exchange within one year of the date of the export invoice, or such further period as the Commissioner allows, the exporter has to pay the tax due with interest, within fifteen days after that year ends. That is the strongest practical reason to keep a tidy trail.
Keep these together per invoice, in one folder:
| Record | What it proves |
|---|---|
| The signed contract or order with the foreign client | That the client is outside India and what you agreed to supply |
| The invoice PDF and its number | What you billed, with the endorsement |
| The LUT acknowledgment for that financial year | That you filed before supplying |
| Bank credit advice or statement line showing the foreign-currency transfer | That payment arrived, and when |
| Any foreign inward remittance certificate your bank issues | The bank's confirmation of the foreign origin of funds |
| Your note of the exchange rate source | How you reached the rupee figure |
Ask your bank what remittance document it provides for inbound payments and how to request it. If you receive money through a platform rather than a SWIFT transfer, the comparison in Payoneer vs Wise for freelancers is worth reading before you pick one, because the platform's statements become your evidence. Your accountant will also tell you how long to keep the records. Do not rely on a number from a blog.
You also report the supply in your GST return, and the circulars show where mistakes in earlier returns can be corrected. That is the accountant's part of the job. Your part is to hand them clean invoices and a bank trail.
Frequently asked questions
Do I need GST registration to export services?
The LUT is something a registered person furnishes, so the practical answer for filing one is yes. Whether you are required to register in the first place depends on your turnover, your state and the nature of your supplies, and I did not verify those thresholds on an official page for this article. Take that question to a chartered accountant before your first export invoice.
What exact sentence goes on an LUT invoice?
The rule 46 proviso uses this wording: "SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX". Use it as written, on the invoice itself, not only in an email or attachment. Add your LUT reference and financial year nearby so a reviewer can match them.
Can I invoice in USD and report in INR?
Yes in practice: the invoice carries the USD amount as the billed figure, and your books record the rupee equivalent at a documented rate. CBIC's circular 8/8/2017-GST confirms export invoices can be in convertible currency or in rupees. How you choose the conversion rate for the return is a point to settle with your accountant, then apply the same way every time.
Does an LUT need renewing every year?
Yes. The LUT is valid for the whole financial year in which it is tendered, which is why it comes back to the top of your to-do list each April. File the new one before your first export invoice of the new year, not after.
Once the LUT is filed and your accountant has agreed the wording, issuing the invoice takes a minute. Open billable.dev, choose your currency, set the tax label to "IGST @ 0% (export under LUT)", paste the endorsement into the notes, and generate the PDF free. No account, and the client data stays in your browser.