An export invoice for services is a tax invoice under section 31 of the CGST Act and Rule 46 of the CGST Rules, issued within 30 days of the supply. In addition to the usual particulars — supplier's name, address and GSTIN; a consecutive serial number unique for the financial year; date; recipient's name and address; SAC code; description; value; and signature — an export invoice must carry the endorsement "SUPPLY MEANT FOR EXPORT UNDER LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX" (or "…ON PAYMENT OF INTEGRATED TAX" if tax is charged), together with the recipient's name, address and country of destination. Where the supplier's aggregate turnover exceeds the e-invoicing threshold (₹5 crore in any year from 2017-18), the export invoice must also be registered on the Invoice Registration Portal and carry the IRN and QR code.
Key facts
| Provision | Old reference (to 31 Mar 2026) | New reference (from 1 Apr 2026) | Rate / threshold | Timing | Form |
|---|---|---|---|---|---|
| Time limit — tax invoice for services | s. 31(2) CGST Act; Rule 47 | Unchanged | — | Within 30 days of supply (45 days for banks/insurers) | — |
| Contents of tax invoice | Rule 46 CGST Rules | Unchanged | Clauses (a) to (r) | — | — |
| Export endorsement and destination details | Third proviso to Rule 46 | Unchanged | Endorsement; recipient's name, address, country of destination; delivery address | — | — |
| E-invoicing | Rule 48(4); Notification 13/2020-CT as amended | Unchanged | Aggregate turnover > ₹5 crore in any FY from 2017-18 (from 1 Aug 2023) | IRN before issue | IRP |
| Reporting | GSTR-1 Table 6A; GSTR-3B 3.1(b) | Unchanged | — | Monthly/quarterly | GSTR-1 |
| Export of services value for refund | Rule 89(4) — turnover of zero-rated supply of services | Unchanged | Payments received for services completed in the period (adjusted for advances) | — | RFD-01 Statement 3 |
The Rule 46 list applied to an export of services
| Rule 46 item | What to put on an export services invoice |
|---|---|
| (a) Supplier's name, address, GSTIN | The Indian company's registered particulars for the state from which the service is supplied |
| (b) Serial number | Consecutive, unique for the financial year, up to 16 characters; a separate series for exports is permitted and convenient |
| (c) Date of issue | Within 30 days of completion of the service or the end of the agreed billing period |
| (d)/(e) Recipient details | Foreign recipient's legal name and full address (unregistered recipient, so no GSTIN); add the country of destination per the proviso |
| (g) HSN / SAC | Six-digit SAC for the service (e.g. 998314 for IT design and development; 998313 for IT consulting and support; 998311 for management consulting) — six digits are mandatory for turnover above ₹5 crore |
| (h) Description | Match the agreement: "Software development services for [period] under agreement dated …" |
| (j)/(k) Value and taxable value | In the invoicing currency with the INR equivalent at the rate applied (state the rate and source, e.g. RBI reference rate of the invoice date); pass-through reimbursements on separate lines |
| (l)–(n) Rate and amount of tax | "IGST: 0% — zero-rated supply under LUT" if under LUT; or IGST at the applicable rate if exporting on payment of tax |
| (o) Place of supply with State name | "Place of supply: [Country] — section 13(2) IGST Act"; many systems require a state code: use 96/97 "Other territory/Other country" as the portal expects |
| (p) Address of delivery | Recipient's address, if different |
| (q) Reverse charge | "No" |
| (r) Signature / DSC | Authorised signatory; digital signature acceptable |
| Proviso — endorsement | "SUPPLY MEANT FOR EXPORT UNDER LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX" (or "…ON PAYMENT OF INTEGRATED TAX"); add the LUT ARN and financial year — not mandatory but routinely requested in refund processing |
| E-invoice | IRN, acknowledgement number and date, signed QR code, if e-invoicing applies |
Three points that cause refund queries
Currency and conversion
Rule 34 of the CGST Rules prescribes the exchange rate for determining value: for services, the rate determined under the generally accepted accounting principles on the date of time of supply. State the rate and the source on the invoice, apply it consistently, and reconcile the INR turnover in GSTR-1 to the books. Refund officers compare invoice INR values with FIRA amounts; small conversion differences are normal and should be explained in the refund covering letter.
Advances
If the parent pays in advance, section 31(3)(d) requires a receipt voucher, and the time of supply for the advance is the date of receipt. Export turnover for Rule 89(4) excludes advances for services not yet supplied and includes earlier advances for services supplied in the period.
Credit and debit notes
Year-end true-ups are documented through credit or debit notes under section 34, referencing the original invoices, and reported in GSTR-1. A credit note reducing export turnover must be declared by 30 November following the financial year or the date of the annual return, whichever is earlier.
E-invoicing applies to exports
E-invoicing under Rule 48(4) is mandatory for registered persons whose aggregate turnover in any financial year from 2017-18 exceeded ₹5 crore (threshold effective 1 August 2023). Exports are B2B supplies for this purpose and must be reported to the Invoice Registration Portal with document type "EXPWOP" (export without payment) or "EXPWP" (with payment). An export invoice issued without an IRN by a person required to e-invoice is not a valid tax invoice, and GSTR-1 auto-population will not pick it up.
Worked example
Invoice header for an Indian subsidiary's monthly bill to its UK parent:
| Supplier | [Indian company], Bengaluru, GSTIN 29XXXXXXXXXXXZ5 |
| Invoice no. / date | EXP/26-27/007 — 5 November 2026 (services for October 2026; within 30 days) |
| Recipient | [UK parent] Ltd, [address], London, United Kingdom — unregistered; country of destination: United Kingdom |
| SAC / description | 998314 — Software development services for October 2026 under Intercompany Services Agreement dated 1 April 2026 |
| Value | GBP 180,000.00 @ ₹105.20 (RBI reference rate, 5 Nov 2026) = ₹1,89,36,000.00 |
| Pass-through (separate line) | Cloud capacity recharged at cost as pure agent — GBP 9,500.00 = ₹9,99,400.00 |
| Tax | IGST 0% — zero-rated supply; place of supply: United Kingdom (s. 13(2) IGST Act); reverse charge: No |
| Endorsement | SUPPLY MEANT FOR EXPORT UNDER LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX — LUT ARN AD2903260000XXX, FY 2026-27 |
| E-invoice | IRN and QR code (turnover above ₹5 crore) |
Common mistakes we see
- Omitting the export endorsement or the country of destination, which are specifically required by the proviso to Rule 46.
- Raising quarterly or annual invoices for monthly services, breaching the 30-day rule and distorting the refund periods.
- Not generating an IRN for export invoices once turnover crosses ₹5 crore, on the assumption that e-invoicing is for domestic B2B only.
- Using a different exchange rate on the invoice, in GSTR-1 and in the books, so the three never reconcile in the refund audit.
- Mixing pass-through reimbursements into the service line, which breaks the pure-agent treatment and the transfer pricing pass-through position.
- Issuing the year-end credit note after the section 34 deadline.
Frequently asked questions
What endorsement must appear on an export invoice under LUT?
"SUPPLY MEANT FOR EXPORT UNDER LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX", per the proviso to Rule 46 of the CGST Rules. If IGST is charged, the wording is "…ON PAYMENT OF INTEGRATED TAX".
Within how many days must a services export invoice be issued?
Within 30 days of the supply of the service, under section 31(2) of the CGST Act read with Rule 47 (45 days for banks, insurers and NBFCs).
Is e-invoicing required for export invoices?
Yes, if the supplier's aggregate turnover exceeded ₹5 crore in any financial year from 2017-18 onwards. Exports are reported to the IRP as EXPWOP or EXPWP.
Which SAC code applies to software development for a foreign parent?
Commonly 998314 (information technology design and development services); IT consulting and support typically fall under 998313. Use the code that matches the service actually supplied.
Should the invoice be in foreign currency or INR?
Either. Show the foreign-currency amount and the INR equivalent with the rate used. GSTR-1 and the refund claim are in INR.
Can I show the LUT number on the invoice?
Yes, and it is good practice — the ARN and financial year of the LUT are routinely asked for in refund processing.
Sources
Primary sources only. Statutory text is read from the official publication; where a provision has been renumbered, the pre-2026 reference is given alongside so older material can be reconciled.
- CGST Act, IGST Act, CGST Rules and GST circulars — CBIC
- GST portal — LUT (Form GST RFD-11), refunds and returns
Last reviewed on 1 November 2026 by Monal Agarwal, FCA, VMS Jhunjhunwala & Co. Law stated as at that date; the Income-tax Act, 2025 and Income-tax Rules, 2026 apply from 1 April 2026.
