Guide for Service Exporters
Menu
GST

How do you supply services to an SEZ unit without charging GST?

Verified by:
Editorial team
Published
Last modified
Reading time
6 min read

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 toGoverned byDeadlinePenaltyLast verified
Suppliers outside the zone supplying services to an SEZ unit or developerIGST Act, section 16(1)(b) and section 7(5)(b)14Not applicableIGST applies as a normal inter-State supply if not for authorised operations1428 October 2026
Suppliers using a Letter of Undertaking (LUT) for SEZ suppliesCGST Rules, rule 96A(1)(b) and 96A(6)7Payment within one year of the invoice date, or the FEMA period with any extension if later7IGST with interest728 October 2026
Suppliers claiming a refund of input tax creditCGST Rules, rule 898Not covered on this pageNot applicable28 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 typeApplicableWhyBest for
Registered supplier with an LUTYesRule 96A(6) applies the LUT procedure to SEZ supplies7Regular SEZ clients
Supplier whose service is not for authorised operationsNoSection 16(1)(b) covers only authorised operations1Charging IGST as a normal inter-State supply
Composition taxpayerNoSection 10 of the CGST Act bars inter-State outward supplies, and section 7(5)(b) makes SEZ supplies inter-State46Leaving 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

  1. File the LUT in FORM GST RFD-11 for the financial year, if you have not already. See how to file an LUT.7
  2. Collect SEZ details: the unit's legal name, GSTIN, address in the zone, and confirmation of authorised operations.
  3. 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
  4. Report the supply as a zero-rated supply to an SEZ in your GST return.
  5. 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 deadlineRuleBest for
Letter of Undertaking in FORM GST RFD-11Rule 96A(6)7Supplying without paying IGST
Rule 46 endorsement on the invoiceRule 462Every SEZ invoice under an LUT
Specified officer's endorsement of receipt for authorised operationsSecond proviso to rule 89(1)8Refund claims
Statement of invoices and details and proof of payment by the recipientRule 89(2)(e)8Refund claims
Declaration that tax was not collected from the SEZ unit or developerRule 89(2)(f)8Refund claims
Payment within one year of the invoice date, or the FEMA period with any RBI-permitted extension if laterRule 96A(1)(b), applied by rule 96A(6)7Tracking 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

PointExport of services abroadSupply to an SEZ unit or developer
Legal basisSection 2(6) and 16(1)(a) of the IGST ActSection 16(1)(b) of the IGST Act
Where the recipient isOutside IndiaInside an SEZ in India
Currency of paymentConvertible foreign exchange, or INR where RBI permitsNo currency condition
Purpose testNoneMust be for authorised operations
Tax type if tax appliesIGSTIGST, under section 7(5)(b)
Treated as "export" by the SEZ ActNot relevantYes, section 2(m)(ii)
Best forClients located outside IndiaClients 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. [1]CBIC: IGST Act, 2017, section 16 (zero rated supply), with footnote on 'for authorised operations' from 1 October 2023
  2. [2]CBIC: CGST Rules, 2017 (consolidated), rule 46
  3. [3]Department of Commerce (sezindia.gov.in): Special Economic Zones Act, 2005, section 2 (clauses (c), (m) and (z))
  4. [4]CBIC: IGST Act, 2017, section 7 (inter-State supply), sub-section (5)
  5. [5]CBIC: IGST Act, 2017, section 2 (definitions, clauses (6), (19) and (20))
  6. [6]CBIC: CGST Act, 2017 (as amended up to 31 August 2021), section 10(2)(c) and 10(2A)(b)
  7. [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. [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.