Exporting goods or services from India can involve important GST compliance requirements. For eligible exporters, a Letter of Undertaking (LUT) can help simplify export transactions by allowing qualifying exports to be made without upfront payment of Integrated Goods and Services Tax (IGST), subject to applicable GST provisions.
If your business provides services to overseas clients, exports products internationally, or is planning to expand into global markets, understanding GST LUT filing can help you manage cash flow and maintain proper compliance.
At My Auditor 360, we provide professional assistance with GST LUT filing, document preparation, online submission, and annual compliance support to help eligible businesses navigate the process.
What Is GST LUT Filing?
LUT stands for Letter of Undertaking. Under GST, eligible registered taxpayers can furnish an LUT in Form GST RFD-11 to make qualifying exports without payment of IGST, subject to the applicable conditions.
The GST portal provides an online facility for furnishing an LUT. It is generally associated with the relevant financial year, meaning exporters intending to use this route should plan their filing for each applicable financial year.
A valid LUT can be useful for businesses that want to avoid funding IGST upfront on eligible export transactions and manage their working capital more efficiently.
Why Is GST LUT Important for Exporters?
Without using the LUT route, an exporter may choose to pay IGST on eligible exports and subsequently claim a refund under the applicable procedure. The LUT route provides an alternative for eligible businesses to make qualifying exports without upfront IGST payment.
GST LUT filing can help businesses:
- Export eligible goods without upfront payment of IGST.
- Export eligible services without upfront payment of IGST.
- Reduce the need to allocate working capital towards export IGST.
- Maintain a more organised export invoicing process.
- Plan export-related GST compliance more effectively.
- Explore refunds of eligible accumulated input tax credit (ITC), where permitted under applicable rules.
Important: LUT filing does not remove other GST compliance requirements. Exporters must continue to meet applicable invoicing, return filing, documentation, and export conditions.
Who Can File GST LUT?
GST LUT is relevant to registered persons making eligible zero-rated supplies, including qualifying exports of goods or services, without payment of integrated tax.
Depending on their transactions and eligibility, the following businesses may benefit from LUT filing:
- Manufacturers exporting goods internationally.
- Merchant exporters.
- IT and software development companies serving overseas customers.
- Consultants and professional service providers working with foreign clients.
- Freelancers providing qualifying export services.
- Digital businesses serving international markets.
- Export trading businesses.
- Other GST-registered businesses undertaking eligible export transactions.
Eligible supplies to Special Economic Zone (SEZ) units or developers should also be evaluated under the applicable GST provisions.
Can Service Exporters File LUT?
Yes. GST-registered service providers can use the LUT route when their transactions qualify as exports of services and the relevant statutory conditions are satisfied.
However, receiving payment from a foreign customer does not automatically make a transaction an export of services. The applicable requirements concerning the supplier, recipient, place of supply, and receipt of consideration must be assessed.
Businesses should verify their transaction details before relying on the LUT route.
Benefits of GST LUT Filing
1. Better Working Capital Management
For eligible exports made under LUT, businesses do not need to pay IGST upfront. This can help reduce the initial tax funding requirement and preserve working capital for operational expenses, employee salaries, and business expansion.
2. Smoother Export Invoicing
A valid LUT supports the applicable process for issuing export invoices without payment of IGST. Correct invoice preparation and reporting remain important for GST compliance.
3. Support for International Service Businesses
IT companies, software businesses, consultants, and other eligible service exporters can assess whether LUT is suitable for their overseas transactions.
4. Better Documentation and Record Keeping
Maintaining the LUT acknowledgement alongside export invoices, GST returns, contracts, and payment records can help businesses manage compliance and respond to future queries.
5. Annual Compliance Planning
Because LUT is linked to the relevant financial year, businesses can include filing or renewal in their annual GST compliance calendar rather than waiting until an export transaction is ready.
6. Potential Input Tax Credit Refunds
Eligible exporters making supplies without payment of tax may be able to claim a refund of accumulated eligible ITC through the prescribed process. Refund eligibility and supporting documentation must be assessed separately under the applicable rules.
Documents and Information Required for GST LUT Filing
The information required can vary depending on the taxpayer and filing circumstances. Businesses should generally keep the following details ready:
- GSTIN.
- Legal name and registered business details.
- PAN details.
- Authorised signatory information.
- Previous LUT, where applicable.
- Details required for the LUT declaration.
- Information about the two witnesses required in the portal form.
- Place of filing.
- Digital Signature Certificate (DSC) or access to the applicable Electronic Verification Code (EVC) facility.
Depending on the business and its export activities, supporting records may also include:
- Import Export Code (IEC), where applicable.
- Export invoices.
- Agreements or contracts with overseas customers.
- Shipping and export documentation for goods.
- Foreign remittance or payment evidence for services.
- Bank records.
- Relevant GST return records.
Not every item above must necessarily be uploaded as part of the LUT application. Some records are relevant to the wider export GST compliance process.
How to File GST LUT Online
GST LUT filing is completed through the GST portal. The following steps provide a general overview of the process.
Step 1: Share Your Business Details
Keep your GST registration details, authorised signatory information, and relevant export information ready.
Step 2: Review Eligibility and Information
Check whether the business and its export transactions qualify for the LUT route. Review the information required for the application before proceeding.
Step 3: Prepare Form GST RFD-11
Organise the required declaration details, financial-year selection, previous LUT information where applicable, and other information requested by the portal.
Step 4: Access the GST Portal
Log in to the official GST portal and navigate to:
Services → User Services → Furnish Letter of Undertaking (LUT)
Follow the current portal instructions to complete the application.
Step 5: Verify and Submit
The authorised signatory must complete the applicable verification process, using DSC or EVC as permitted by the portal and the taxpayer’s circumstances.
After successful submission, the portal generates an Application Reference Number (ARN).
Step 6: Save the Acknowledgement
Download and retain the LUT acknowledgement with the business’s GST and export records. Ensure the relevant export invoices and GST returns are handled correctly after filing.
The exact portal interface and filing requirements may change, so refer to the current GST portal instructions when submitting an application.
LUT vs Paying IGST on Exports
Eligible exporters may need to evaluate the available routes based on their circumstances.
| Consideration | Export Under LUT | Export With IGST |
|---|---|---|
| Upfront IGST payment | Not required for eligible exports under a valid LUT | IGST is paid initially |
| Working capital | Avoids upfront IGST funding | Requires initial tax funding |
| Refund process | Eligible accumulated ITC may be claimed separately | Refund of IGST may be available under applicable rules |
| LUT requirement | Required for this route | Not required for the particular payment-of-IGST route |
| Compliance | LUT, export records, and applicable GST returns | Export records, tax payment, refund requirements, and applicable GST returns |
The most appropriate route depends on the business’s transactions, cash-flow requirements, and applicable GST provisions. Businesses should assess the available options before choosing a method.
Common GST LUT Filing Mistakes to Avoid
Even though LUT filing is an online process, incorrect information or a misunderstanding of export conditions can create compliance difficulties.
1. Filing After Starting Exports
The LUT or applicable bond should be furnished before making exports without payment of IGST, as required under the applicable rules. Businesses should plan the filing in advance.
2. Selecting the Wrong Financial Year
LUT is associated with the relevant financial year. Check the period carefully before submitting the application.
3. Treating LUT as a Permanent Registration
LUT is not a permanent certificate that remains valid indefinitely. Businesses intending to use the LUT route should review their requirements for each financial year.
4. Ignoring Export-of-Service Conditions
Overseas customers or foreign-currency payments alone do not establish that every transaction qualifies as an export of services. Review the applicable statutory conditions.
5. Assuming LUT Replaces GST Returns
LUT only supports the eligible route for making qualifying supplies without payment of IGST. Applicable GST returns, invoicing requirements, record keeping, and other compliance obligations continue.
6. Failing to Maintain Export Records
Keep the LUT acknowledgement, invoices, supporting export records, payment evidence where relevant, and GST return information organised.
What Happens If LUT Conditions Are Not Met?
An LUT is an undertaking to comply with the applicable export conditions. Filing the form does not automatically establish that every subsequent transaction qualifies for export treatment.
For example, Rule 96A of the CGST Rules contains requirements relating to the export of goods within the prescribed period and the receipt of payment for export services within the applicable period, subject to relevant provisions and permitted extensions.
If the required conditions are not met, tax and interest consequences may arise.
Businesses should therefore review both the LUT filing and the underlying export transactions. If an export transaction has unusual circumstances or a payment delay, obtain appropriate professional advice on the applicable requirements.
What Is Included in Our GST LUT Filing Service?
My Auditor 360 provides professional assistance to help businesses organise and complete their GST LUT filing requirements.
Depending on the agreed service scope, our assistance may include:
- Eligibility Review: Preliminary assessment of GST and export-related information.
- Information Preparation: Organising the details required for Form GST RFD-11.
- Document Review: Reviewing the information supplied before filing.
- Online Filing Assistance: Guidance through the applicable GST portal process.
- Verification Support: Assistance with the applicable DSC or EVC verification process.
- Acknowledgement Support: Helping you retain the ARN and filed LUT records.
- Annual Compliance Support: Assistance with planning the LUT filing for subsequent financial years, where included in the service.
The exact scope of work should be confirmed before engagement. Professional assistance does not replace the taxpayer’s responsibility to provide accurate information and meet applicable GST requirements.
How Long Does GST LUT Filing Take?
The online process can generally be completed once the required information is available and the authorised signatory completes verification.
The actual time required may depend on document readiness, portal availability, information gaps, and any clarification needed before submission.
After successful filing, the GST portal generates an ARN and provides an acknowledgement facility.
For an accurate service timeline, confirm the expected turnaround with your service provider before proceeding.
GST LUT Filing Cost
GST authorities do not prescribe a universal professional service fee for consultants assisting with LUT filing. Professional fees depend on the service provider and the agreed scope of work.
A service provider may offer different options, such as:
- LUT Filing: Assistance with filing for one financial year.
- LUT Filing + Review: Filing assistance along with a review of the relevant information and documents.
- Export GST Compliance Support: LUT assistance combined with additional export-related GST compliance services.
Contact My Auditor 360 to discuss your requirement and confirm the applicable professional fee before proceeding.
Frequently Asked Questions About GST LUT Filing
1. What is the full form of LUT in GST?
LUT stands for Letter of Undertaking. Eligible registered taxpayers can furnish it in Form GST RFD-11 to make qualifying exports without payment of IGST, subject to applicable conditions.
2. Is GST LUT mandatory for every exporter?
No. LUT is relevant to eligible registered persons who choose to make qualifying exports without payment of IGST. Other applicable export tax routes may be available, depending on the circumstances.
3. Which form is used for GST LUT filing?
The prescribed form is GST RFD-11, which can be furnished through the GST portal.
4. Can GST LUT be filed online?
Yes. The GST portal provides an online facility under Services → User Services → Furnish Letter of Undertaking (LUT).
5. Is LUT required every financial year?
LUT is linked to the relevant financial year. Businesses intending to use the LUT route should furnish a fresh LUT for each financial year in which they intend to rely on it.
6. Can a software company file GST LUT?
A GST-registered software or IT company may use the LUT route if its transactions qualify as exports under the applicable GST provisions.
7. Can freelancers file LUT for overseas clients?
GST-registered freelancers may be eligible if their transactions satisfy the applicable export-of-services conditions. Their individual circumstances should be reviewed before filing.
8. Can an exporter claim an ITC refund after filing LUT?
Potentially, yes. Eligible exporters making supplies without payment of tax may apply for a refund of accumulated eligible ITC through the prescribed process, subject to the applicable conditions.
9. Does LUT remove the requirement to file GST returns?
No. LUT does not replace applicable GST return filing, export invoicing, record keeping, or other statutory compliance requirements.
10. Is LUT the same as GST registration?
No. GST registration identifies a taxpayer under GST, whereas LUT is an undertaking furnished by an eligible registered person to make qualifying exports without payment of IGST.
11. What happens if payment for export services is delayed?
The applicable rules specify requirements concerning receipt of payment for export services, subject to relevant provisions and permitted extensions. If the conditions are not met, tax and interest consequences may arise. The transaction should be reviewed based on the applicable rules.
12. How can I confirm that my LUT has been filed?
After successful submission, the GST portal generates an ARN. You can retain the acknowledgement as evidence of the filing.
Get Professional Assistance With GST LUT Filing
If your business exports goods or services and you want to understand whether the LUT route is suitable, My Auditor 360 can help you review your requirements and understand the filing process.
Our assistance covers the relevant information, document preparation, online filing process, and acknowledgement support, depending on your agreed service scope.
Planning to file your GST LUT?
Share your GSTIN, business type, and whether you export goods or services to help us understand your requirements.
Contact My Auditor 360 for GST LUT Filing Assistance.
Note: GST requirements can vary according to the taxpayer’s circumstances and the applicable law. This article provides general information and is not a substitute for advice based on your specific transactions.
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