Zero-Rated Supply — GST on
Exports & Supplies to SEZ
Exports are the one
area where GST deliberately charges nothing to the overseas buyer — but
'zero-rated' is very different from 'exempt', and understanding that
distinction can meaningfully affect how much cash an exporting business gets
back through refunds.
What Zero-Rated Supply Means
Under Section
16 of the IGST Act, two categories of supply are specifically treated as
'zero-rated supplies': the export of goods or services out of India, and supply
of goods or services to a Special Economic Zone (SEZ) developer or SEZ unit. In
both cases, GST is charged at 0% — but crucially, the exporter or SEZ supplier
remains fully entitled to claim Input Tax Credit on the inputs and input
services used to make that supply, unlike a genuinely exempt supply where no
such credit is available.
Two Routes for Exporters
•
Export under a Letter of Undertaking (LUT) or Bond,
without payment of IGST — the exporter does not charge or pay IGST on the
export invoice, and instead claims a refund of accumulated, unutilised Input
Tax Credit relating to that export
•
Export on payment of IGST — the exporter pays IGST
upfront on the export invoice at the applicable rate, and subsequently claims a
refund of that IGST actually paid, which in the case of goods exports is often
processed largely automatically based on shipping bill and export general
manifest data
Deemed Exports
Certain
domestic supplies, though the goods don't actually leave India, are notified as
'deemed exports' under Section 147 of the CGST Act — such as supply of goods to
Export Oriented Units (EOUs), supply against Advance Authorisation, and supply
of capital goods against Export Promotion Capital Goods (EPCG) authorisation.
These are eligible for a refund mechanism, though typically GST is paid at the
time of supply and refunded later, rather than being zero-rated at the point of
sale.
Key Documentation for Export Refunds
•
Shipping Bill / Bill of Export, filed with Customs, for
export of goods
•
Letter of Undertaking (LUT), filed annually on the GST
portal in Form GST RFD-11, if exporting without upfront tax payment
•
Export invoice, clearly marked as 'SUPPLY MEANT FOR
EXPORT UNDER LUT/BOND WITHOUT PAYMENT OF INTEGRATED TAX' or 'SUPPLY MEANT FOR
EXPORT ON PAYMENT OF INTEGRATED TAX', as applicable
•
Foreign Inward Remittance Certificate (FIRC) or Bank
Realisation Certificate (BRC), as proof of receipt of export proceeds in
convertible foreign exchange, particularly for services
•
For SEZ supplies: an endorsement from the SEZ officer
confirming receipt of goods/services, along with the SEZ unit's Letter of
Approval details
Why Exporters Prefer the LUT Route
Most exporters,
particularly those with a regular export business, prefer the LUT route over
paying IGST upfront and claiming a refund, since it avoids locking up working
capital in tax payments that then need to be recovered through the refund
process — LUT-based exports simply require refunding the accumulated ITC on
inputs, which, while still a process, doesn't involve the exporter funding the
government's tax revenue temporarily on every single export transaction.
💡 Illustration — Export of Services under LUT
An IT company in Bengaluru
exports software services worth $10,000 to a client in the US under a valid
LUT. No GST is charged on this export invoice, but the company can claim a
refund of the GST it paid on office rent, software subscriptions, and other business
inputs used to deliver that service — money that would otherwise sit locked up
as unutilised credit.
💡 Illustration — Supply to an SEZ Unit
A domestic manufacturer
supplies raw materials to a unit operating within a Special Economic Zone in
the same state. Even though both the supplier and the SEZ unit are physically
located within India (and even within the same state), this supply is still
treated as a zero-rated supply under GST law, and the manufacturer can supply
either under LUT (without charging IGST) or on payment of IGST with a
subsequent refund claim.
⚠ Common Mistakes to Avoid
• Forgetting to
file or renew the LUT at the start of each financial year, which can force a
business back into the pay-IGST-and-claim-refund route unintentionally
• Not
maintaining proper linkage between export invoices and the corresponding
shipping bills, complicating refund claims
• Missing the
requirement to actually realise export proceeds in convertible foreign exchange
within the prescribed time limit for services exports
• Treating a domestic sale to an unrelated
foreign buyer's Indian subsidiary as an export, when in fact both parties may
be located within India for GST purposes
Frequently Asked Questions
Q1.
Is GST charged on exports from India?
A. No — exports are zero-rated, meaning the GST rate
applicable is effectively 0%, and no tax is charged to the overseas buyer,
while the exporter retains full ITC eligibility on related inputs.
Q2.
What's the difference between 'zero-rated' and 'exempt' supply?
A. Both mean no tax is charged to the customer, but a
zero-rated supplier can still claim and get a refund of Input Tax Credit
related to that supply, while a supplier of an exempt supply cannot claim any
ITC at all on inputs used for that supply.
Q3.
What is an LUT and why does it matter?
A. A Letter of Undertaking is a self-declaration
filed annually by an exporter on the GST portal, allowing them to export
without paying IGST upfront — avoiding the cash flow hit of paying tax and then
waiting for a refund on every export transaction.
Q4.
Are supplies to an SEZ always zero-rated, even within the same state?
A. Yes, supplies to an SEZ developer or SEZ unit are
treated as zero-rated supplies under the IGST Act, regardless of whether the
supplier and the SEZ are located in the same state or different states.
Q5.
What documents are essential for claiming an export-related GST refund?
A. Primarily the shipping bill/bill of export (for
goods) or FIRC/BRC (for services), the relevant export invoices, and the LUT
(if exporting without IGST payment) — all linked together for the refund
application.
Q6.
What are deemed exports, and how do they differ from actual exports?
A. Deemed exports are specifically notified domestic
supplies (like to EOUs, or against Advance Authorisation/EPCG) where the goods
never actually leave India, but which are still granted export-like refund
benefits due to their role in supporting India's export ecosystem.
✓ Key Takeaways
• Exports and
SEZ supplies are 'zero-rated' — taxed at 0%, but with full ITC eligibility
retained, unlike exempt supplies
• Exporters can
choose between the LUT route (no upfront IGST) or paying IGST and claiming a
refund
• Proper
documentation — shipping bills, LUT, FIRC/BRC — is essential to actually realise
the refund
• Deemed exports (EOU/Advance
Authorisation/EPCG supplies) get similar refund treatment despite goods not
physically leaving India
Note: GST rates, thresholds and procedures are revised periodically by the GST Council and CBIC. This article reflects the position understood as of the GST 2.0 rate structure (effective 22 September 2025). Please verify current figures on www.gst.gov.in or with a qualified tax professional before making compliance decisions.
Disclaimer
This content is shared strictly for general information and knowledge purposes only. Readers should independently verify the information from reliable sources. It is not intended to provide legal, professional, or advisory guidance. The author and the organisation disclaim all liability arising from the use of this content. The material has been prepared with the assistance of AI tools.
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