GST Export Compliance: LUT Witness Affidavit & Invoice Setup
A complete compliance guide for exporting services from India under GST. Includes downloadable templates for the LUT Witness Affidavit and a FEMA-compliant invoice.
Understanding GST Zero-Rated Exports
Under the Indian GST framework, export of services is treated as a "Zero-Rated Supply" under Section 16 of the Integrated Goods and Services Tax (IGST) Act, 2017. This allows exporters, agency owners, and freelancers to supply services to overseas clients without paying any tax. However, to enjoy this tax-free status, you must comply with strict registration and invoicing rules.
The most common and cost-effective pathway to export services is the LUT (Letter of Undertaking) Route. By submitting Form GST RFD-11 at the start of each fiscal year, you can export services at 0% GST and avoid locking up 18% of your revenue in tax refunds.
The Witness Requirement for LUT (Form RFD-11)
When you file a Letter of Undertaking on the GST portal, you are executing a legal contract with the Government of India. The GST portal requires you to enter the details of two independent witnesses. If your GST filings are ever selected for a scrutiny audit, the GST officer may request a physical copy of the witness declarations or affidavits confirming their signature and identity.
Below is a downloadable compliance template for the LUT Witness Declaration. You should fill this out, have both witnesses sign it, and keep a scanned copy in your compliance records.
Downloadable Template
GST LUT Witness Declaration Sheet
Complete witness declaration sheet to support your Form GST RFD-11 filing in case of audits. Keep this signed PDF/copy in your tax file.
GST & FEMA-Compliant Export Invoicing
To satisfy bank compliance officers and ensure that your foreign inward remittance is correctly reported to the RBI under the correct purpose code, your invoices must contain specific legal declarations.
A standard domestic invoice will fail bank audits. A service export invoice must include:
- Your GSTIN and LUT ARN number (Letter of Undertaking ARN).
- The mandatory legal declaration under Rule 46 of the CGST Rules: "Supply of services for export without payment of integrated tax under LUT."
- The correct FEMA Purpose Code (e.g.
P0802for software consultancy). - Clear details of the billing currency (USD/EUR) and equivalent INR.
Downloadable Template
FEMA & GST-Compliant Export Invoice Structure
Complete export invoice formatting template including LUT declarations, FEMA purpose code declarations, and bank remittance fields.
Reconciling Invoices with FIRC / FIRA
Once your client pays, the inward transaction will settle in your Indian bank account. The bank will issue a Foreign Inward Remittance Advice (FIRA). Ensure that the total amount in INR matches the entry in your GSTR-1 returns, and verify that the bank has attached the correct purpose code (e.g. P0802) to the remittance record. Keeping this documentation reconciled protects your business from GST audits and verification letters from the tax department.