How do you supply services to an SEZ unit without charging GST?
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Short answer
Services supplied to an SEZ unit or developer for its authorised operations are zero-rated under IGST Act section 16(1)(b).1 The "for authorised operations" condition applies from 1 October 2023.1 The supplier usually files an LUT and invoices without IGST with the rule 46 endorsement.27 An ITC refund needs the specified officer's endorsement and payment proof under rule 89.8
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Suppliers outside the zone supplying services to an SEZ unit or developer | IGST Act, section 16(1)(b) and section 7(5)(b)14 | Not applicable | IGST applies as a normal inter-State supply if not for authorised operations14 | 28 October 2026 |
| Suppliers using a Letter of Undertaking (LUT) for SEZ supplies | CGST Rules, rule 96A(1)(b) and 96A(6)7 | Payment within one year of the invoice date, or the FEMA period with any extension if later7 | IGST with interest7 | 28 October 2026 |
| Suppliers claiming a refund of input tax credit | CGST Rules, rule 898 | Not covered on this page | Not applicable | 28 October 2026 |
Plenty of Indian service providers bill clients who sit inside a Special Economic Zone (SEZ): IT and back-office companies in SEZ campuses hire designers, trainers, recruiters, consultants, auditors and software subcontractors from outside the zone. Under GST, these supplies can be zero-rated, much like exports, but the rules and paperwork are different.12
This guide is written for the supplier outside the zone, in what the SEZ law calls the Domestic Tariff Area (DTA). For how money flows into and out of SEZ units, see SEZ export payment rules. The position is stated as of 28 October 2026.13
What is a zero-rated supply of services to an SEZ unit?
A zero-rated supply of services to an SEZ unit is a supply for the unit's authorised operations, which section 16(1)(b) of the Integrated Goods and Services Tax (IGST) Act treats as zero-rated.1 The section covers a "supply of goods or services or both for authorised operations to a Special Economic Zone developer or a Special Economic Zone unit".1
- Condition added: the words "for authorised operations" were inserted by the Finance Act, 2021 and brought into force from 1 October 2023.1
- Definitions: the terms SEZ, SEZ unit and SEZ developer take their meaning from the Special Economic Zones Act, 2005 (the SEZ Act), under section 2(19) and 2(20) of the IGST Act.5
- Authorised operations: the operations that may be authorised for a developer under section 4(2) of the SEZ Act or for a unit under section 15(9), as defined in section 2(c).3 In practice, the unit's approval documents list what it is allowed to do in the zone.
For example, software development subcontracted by an IT services unit, payroll processing for a back-office unit, or design work for an electronics unit's products typically fit. A team dinner organised for staff, or a service for the parent company's operations outside the zone, may not.
Who can supply services to an SEZ unit without charging GST?
A registered supplier outside the zone can supply services to an SEZ unit without charging GST when the service is for the unit's authorised operations, usually under a Letter of Undertaking (LUT).17
| Entity type | Applicable | Why | Best for |
|---|---|---|---|
| Registered supplier with an LUT | Yes | Rule 96A(6) applies the LUT procedure to SEZ supplies7 | Regular SEZ clients |
| Supplier whose service is not for authorised operations | No | Section 16(1)(b) covers only authorised operations1 | Charging IGST as a normal inter-State supply |
| Composition taxpayer | No | Section 10 of the CGST Act bars inter-State outward supplies, and section 7(5)(b) makes SEZ supplies inter-State46 | Leaving the scheme before SEZ work |
How do you invoice an SEZ unit without IGST?
You invoice an SEZ unit without IGST by furnishing an LUT, endorsing the invoice under rule 46 and keeping the evidence for any refund.278
- File the LUT in FORM GST RFD-11 for the financial year, if you have not already. See how to file an LUT.7
- Collect SEZ details: the unit's legal name, GSTIN, address in the zone, and confirmation of authorised operations.
- Endorse the invoice. Rule 46 requires the endorsement "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".2
- Report the supply as a zero-rated supply to an SEZ in your GST return.
- Get the specified officer's endorsement and payment proof you will need for any refund, as described below.8
See the export invoice format for the other invoice fields.
What documents and deadlines apply to supplies of services to an SEZ unit?
The documents for supplies of services to an SEZ unit are the LUT, the endorsed invoice and the rule 89 refund evidence, and the deadline is the rule 96A payment period.278
| Document or deadline | Rule | Best for |
|---|---|---|
| Letter of Undertaking in FORM GST RFD-11 | Rule 96A(6)7 | Supplying without paying IGST |
| Rule 46 endorsement on the invoice | Rule 462 | Every SEZ invoice under an LUT |
| Specified officer's endorsement of receipt for authorised operations | Second proviso to rule 89(1)8 | Refund claims |
| Statement of invoices and details and proof of payment by the recipient | Rule 89(2)(e)8 | Refund claims |
| Declaration that tax was not collected from the SEZ unit or developer | Rule 89(2)(f)8 | Refund claims |
| Payment within one year of the invoice date, or the FEMA period with any RBI-permitted extension if later | Rule 96A(1)(b), applied by rule 96A(6)7 | Tracking unpaid SEZ invoices |
Although the currency of payment does not matter, actual payment by the SEZ recipient does matter for the refund.18 See refund of ITC on zero-rated supplies.
What happens if the SEZ unit does not pay or the endorsement is refused?
If the specified officer does not endorse receipt for authorised operations, the refund evidence required by rule 89 is missing, and the zero-rating itself may be questioned under section 16(1)(b).18
- No payment: rule 89(2)(e) payment evidence is missing, and rule 96A(1)(b) binds the supplier to pay IGST with interest if payment for services supplied under an LUT is not received within one year of the invoice date, or the period allowed under the Foreign Exchange Management Act (FEMA) including any RBI-permitted extension if that is later (or a further period the Commissioner allows).78
- Rule 96A(6): applies that sub-rule to SEZ supplies.7
- Rupee payments: how rule 96A(1)(b) applies to a rupee payment from an SEZ unit, since that clause speaks of payment in convertible foreign exchange or in rupees where the RBI permits, is not settled in any CBIC circular we could find.7
Treat collection as essential and confirm the position with a chartered accountant if a payment is overdue.
How is a supply to an SEZ unit different from exporting a service abroad?
A supply to an SEZ unit is a different kind of zero-rated supply from an export of services, with a different legal test.15
| Point | Export of services abroad | Supply to an SEZ unit or developer |
|---|---|---|
| Legal basis | Section 2(6) and 16(1)(a) of the IGST Act | Section 16(1)(b) of the IGST Act |
| Where the recipient is | Outside India | Inside an SEZ in India |
| Currency of payment | Convertible foreign exchange, or INR where RBI permits | No currency condition |
| Purpose test | None | Must be for authorised operations |
| Tax type if tax applies | IGST | IGST, under section 7(5)(b) |
| Treated as "export" by the SEZ Act | Not relevant | Yes, section 2(m)(ii) |
| Best for | Clients located outside India | Clients operating inside an Indian SEZ |
The table summarises sections 2(6), 7(5) and 16 of the IGST Act and section 2(m) of the SEZ Act.1345 Section 2(m)(ii) of the SEZ Act defines export to include "supplying goods, or providing services, from the Domestic Tariff Area to a Unit or Developer".3
What are the common mistakes with supplies of services to an SEZ unit?
The common mistakes with supplies of services to an SEZ unit are skipping the authorised-operations check and filing a refund without the endorsement and payment proof.18
- No authorised-operations check: ask the SEZ unit for confirmation that your service is used for its authorised operations before you invoice without tax.1
- Charging CGST and SGST: section 7(5)(b) makes every SEZ supply inter-State, so if tax applies it is IGST.4
- Missing endorsement: the invoice needs the rule 46 wording.2
- Filing a refund too early: collect payment and the specified officer's endorsement before you file under rule 89.8
- Composition scheme: composition taxpayers cannot make this supply at all.46
Confirm unusual cases with a chartered accountant.
How did we verify this?
We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.
- [1]CBIC: IGST Act, 2017, section 16 (zero rated supply), with footnote on 'for authorised operations' from 1 October 2023
- [2]CBIC: CGST Rules, 2017 (consolidated), rule 46
- [3]Department of Commerce (sezindia.gov.in): Special Economic Zones Act, 2005, section 2 (clauses (c), (m) and (z))
- [4]CBIC: IGST Act, 2017, section 7 (inter-State supply), sub-section (5)
- [5]CBIC: IGST Act, 2017, section 2 (definitions, clauses (6), (19) and (20))
- [6]CBIC: CGST Act, 2017 (as amended up to 31 August 2021), section 10(2)(c) and 10(2A)(b)
- [7]CBIC: CGST Rules, 2017, rule 96A (export under bond or Letter of Undertaking), clause (1)(b) as substituted by Notification No. 12/2024-Central Tax, 10 July 2024, and sub-rule (6)
- [8]CBIC: CGST Rules, 2017, rule 89 (application for refund), second proviso to sub-rule (1) and sub-rule (2)(e) and (f)
Frequently asked questions
Is a supply to an SEZ unit an export of services under GST?+
A supply to an SEZ unit is not an export of services under section 2(6) of the IGST Act, which needs a recipient outside India.5 It is a separate category of zero-rated supply under section 16(1)(b).1 The SEZ Act separately calls such a supply an export for SEZ purposes under section 2(m)(ii).3
Can an SEZ unit pay a service supplier in rupees?+
Yes, as far as GST zero-rating goes. Section 16(1)(b) of the IGST Act has no condition about the currency of payment, unlike the export of services definition in section 2(6).15 Actual payment by the SEZ recipient still matters, because rule 89 asks for proof of payment when you claim a refund.8
Should a supplier charge CGST and SGST if the SEZ unit is in the same State?+
No. Section 7(5)(b) of the IGST Act treats every supply to an SEZ unit or developer as inter-State, so if tax applies it is IGST.4 This holds even when the supplier and the SEZ unit are in the same State, so CGST and SGST do not apply to the invoice.
What if a service to an SEZ unit is not for the unit's authorised operations?+
A service that is not for the SEZ unit's authorised operations is not zero-rated under section 16(1)(b) as amended from 1 October 2023, and IGST applies as on a normal inter-State supply.14 Ask the SEZ unit for written confirmation of authorised operations before invoicing without tax.
What does a supplier need to claim a refund of input tax credit on SEZ supplies?+
Rule 89 of the CGST Rules requires evidence that the services were received for authorised operations, endorsed by the specified officer of the zone, details and proof of payment by the SEZ recipient, and a declaration that tax was not collected from the SEZ unit or developer.8 Collect these before filing the refund application.
Can a composition taxpayer supply services to an SEZ unit?+
No. Section 10 of the CGST Act bars composition taxpayers from making inter-State outward supplies, and section 7(5)(b) of the IGST Act makes every supply to an SEZ unit or developer inter-State.46 A composition taxpayer would need to leave the scheme before taking on SEZ work.
This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.
Keep reading
What payment rules apply to SEZ units exporting services and to their suppliers?
How payments work for SEZ service exporters and their suppliers in 2026: EDF to the Development Commissioner, nine-month realisation, positive NFE, and rupee payments.
GlossaryWhat is an SEZ?
An SEZ is a zone notified under the SEZ Act, 2005 that is treated as outside India's customs territory. What it means for Indian service exporters.
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Step-by-step guide to filing a Letter of Undertaking in FORM GST RFD-11 for export of services: eligibility, validity, late filing and the ARN on invoices.
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