GST LUT for freelancers and software exporters: how to file Form RFD-11

Who needs an LUT

Only GST-registered exporters. Registration is compulsory once your aggregate turnover crosses ₹20 lakh in a financial year (₹10 lakh in Manipur, Mizoram, Nagaland and Tripura), and export turnover counts towards it. If you are not registered (and not required to register on other grounds), you issue a plain invoice without GST and need no LUT.

Without an LUT, a registered exporter has to charge IGST on exports and claim it back as a refund. That route still exists, but it is rarely sensible for freelancers.

When to file

• Before your first export invoice of each financial year (April to March). An LUT is valid for one financial year, so file a new one every year; March is a good time.
• It shows as "Deemed Approved" after 3 working days.
• If you invoiced before filing it, a late LUT can be condoned (Circular 37/11/2018, as commonly reported). Ask your CA.

How to file it on the GST portal

1. Log in to the GST portal.
2. Go to Services → User Services → Furnish Letter of Undertaking (LUT).
3. Choose the financial year.
4. Fill the declarations and the details of two witnesses.
5. Sign with EVC (OTP) or a digital signature and submit.
6. Note the ARN shown after submission and keep it. Showing it on your invoices is good practice, not a legal requirement.

What goes on the invoice

Under an LUT, your export tax invoice shows IGST at 0% and this endorsement, word for word:

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

Also show your GSTIN, a unique invoice number of up to 16 characters, the client's name and address, the country of destination, place of supply "Outside India", the SAC code (reportedly optional on invoices to foreign clients up to ₹5 crore turnover, but the EDF asks for it) and the value (CGST Rule 46). Showing the LUT's ARN and financial year is good practice. The free invoice generator adds all of this.

If the money never arrives

The LUT comes with a condition. If you aren't paid within the later of one year from the invoice date and the RBI period (9 months, plus any extension your bank grants), you must pay the IGST with 18% interest within 15 days after that date (Rule 96A). You can claim it back once the money arrives. The due date calculator shows the date for any invoice.

Reporting exports in your returns

• GSTR-1, Table 6A: each export invoice as "without payment of tax" (WOPAY), with the value in rupees at the exchange rate for the time of supply (CGST Rule 34(2); usually the invoice date). Exports can't go in the IFF.
• GSTR-3B, Table 3.1(b): the zero-rated value, with IGST at 0.
• A month or quarter with any export invoice is never a NIL return, even if no tax is payable.

Sources: CGST Rules 46 and 96A; GSTN's LUT tutorial; Circular 37/11/2018-GST. This is a summary, not tax advice.