Is your work an export of services?

A foreign client does not by itself make your work an export. Section 2(6) of the IGST Act sets five conditions, and the supply is an export of services only when all five hold.¹ The Export of Services Checker walks through them one by one.

What does the Export of Services Checker check?

The Export of Services Checker checks your contract against the five conditions in section 2(6) of the Integrated Goods and Services Tax (IGST) Act.¹ A supply of services is an export only when:¹

1. the supplier of the service is located in India,
2. the recipient of the service is located outside India,
3. the place of supply of the service is outside India,
4. the payment is received by the supplier in convertible foreign exchange or in Indian rupees wherever permitted by the Reserve Bank of India, and
5. the supplier and the recipient are not merely establishments of a distinct person (for example, an Indian branch billing its own foreign head office).

All five must be true. Exports that meet them are zero-rated supplies under section 16 of the IGST Act.³

How does the Export of Services Checker reach its result?

The Export of Services Checker counts the conditions you tick, and shows "Likely a zero-rated export" only when all five are ticked.¹³ There is no weighting: one missing condition means the supply is not an export.¹

• Five of five: likely a zero-rated export, so you can invoice under an LUT without charging IGST.³
• Four or fewer: a reminder that all five conditions must hold.¹

For example, say a developer in Pune builds an app for a company in Germany, works from India and is paid in euros into an Indian bank. All five conditions hold, so the supply is a zero-rated export.¹³ Say instead an Indian branch bills its own head office in London: condition 5 fails, so the supply is not an export.¹⁴

How do you use the Export of Services Checker?

You use the Export of Services Checker by ticking each condition that is true for one contract and reading the result.

1. Have the contract or invoice in front of you, with the client's location, where the work is done and how you are paid.
2. Tick each of the five conditions that is true for that contract.
3. Read the result: all five ticked shows a likely zero-rated export; fewer shows a reminder.
4. If all five hold, file an LUT, raise an export invoice with the LUT endorsement and keep proof of the foreign payment.

Run the checker once per contract, because the answer can differ between clients.

What does an Export of Services Checker result mean?

An Export of Services Checker result of five out of five means the supply is likely zero-rated, so you can invoice it without IGST under a Letter of Undertaking.³ Anything less means the supply is not an export of services.¹

• Five of five: file an LUT for the financial year, raise an export invoice with the LUT endorsement, and keep proof of the foreign payment, such as a FIRA, for each invoice.
• Four or fewer: the supply is usually an ordinary taxable supply, so GST applies at the normal rate if you are registered.¹

The result says "likely" because the checker relies on your answers and does not test them.

What does the Export of Services Checker assume, and what does it not cover?

The Export of Services Checker assumes your answers to each condition are correct, especially on place of supply.¹²

• Rates used: none. The checker applies conditions, not tax rates.
• Taxes included: GST only. Income tax and foreign withholding are outside it.
• Not covered: where the place of supply is for an unusual contract, whether you must register for GST, and how income tax applies.

For a contract with mixed elements, such as part of the work performed on goods in India, confirm the treatment with a chartered accountant.

What do people get wrong about the export of services conditions?

Most mistakes about the export of services conditions involve place of supply and the related-party condition.¹²⁴

• Place of supply: for most services the place of supply is the location of the recipient, so a foreign client means a foreign place of supply.² Some services follow special rules, for example services relating to immovable property in India or services performed on goods physically in India.²
• Intermediary services: these followed a special rule, section 13(8)(b), until the Finance Act, 2026 omitted it with effect from 30 March 2026.²⁵ Read intermediary services and export status if you act as an agent between a foreign client and other suppliers.
• Related entities: CBIC Circular No. 161/17/2021-GST clarifies that an Indian subsidiary supplying services to its foreign parent is not merely an establishment of a distinct person, because the two are separate legal entities, so the export can still qualify. An Indian branch billing its own foreign head office does not.⁴

Checking these three points covers most disputed cases.

Which rules should you know about export of services under GST?

The rules to know about export of services under GST are sections 2(6), 13 and 16 of the IGST Act, Circular No. 161/17/2021-GST, and a pending GST Council recommendation.¹²³⁴⁶

Note: On 8 October 2026 the GST Council (57th meeting) recommended omitting condition 5 altogether. That needs Parliament to amend the IGST Act, so as of 28 October 2026 the condition still applies.¹⁶

Read the GST on export of services guide for the full treatment.