Export service invoice: what to issue when a foreign client has no GSTIN

Issue the export tax invoice using your GSTIN and the foreign customer’s legal name, address and country. A customer without an Indian GSTIN can still receive your invoice. Do not invent a recipient GSTIN. CBIC: GSTR-1 instructions.

This example covers a GST-registered Indian business supplying a taxable service directly to an overseas customer under LUT.

Confirm the export treatment before invoicing

Check all five conditions: the supplier is in India; the recipient and place of supply are outside India; consideration is received in convertible foreign exchange or RBI-permitted rupees; and the parties are not merely establishments of the same person under the statutory test. A foreign address alone is insufficient. CBIC Circular 202/14/2023-GST, paragraph 3.1.

Services to your foreign parent or group company can qualify. CBIC has clarified that a company incorporated in India and a body corporate incorporated abroad are separate persons, so they are not “merely establishments of a distinct person”. A supply from an Indian company to its own branch or office abroad that is not incorporated there is different: it cannot be treated as an export. CBIC Circular 161/17/2021-GST, paragraphs 4.3 and 5.1. The GST Council has recommended removing that condition for branches; see services to your own foreign branch.

Confirm the LUT for the relevant financial year. For app-marketplace sales, first resolve the contractual recipient using the App Store guide.

Worked invoice: a completed software-development milestone

All names, dates and amounts below are fictional. Assume the export conditions are satisfied, an LUT covers FY 2026–27, and the agreed milestone price is INR 12,000. Replace every bracketed field before issuing an invoice.

Invoice field	Example entry
Document	Tax invoice — export under LUT
Supplier	Example Studio (fictional); [registered address, state and postcode], India
Supplier GSTIN	[your GSTIN]
Invoice number and date	EX26-001; 08-04-2026
Recipient	Example Overseas Ltd (fictional)
Recipient address	[building/street], [city], [postcode], United Kingdom
Recipient Indian GSTIN	Not applicable — overseas customer
Delivery address	Same as recipient address, if correct
Place of supply / destination	United Kingdom, based on the reviewed supply
Service	Software-development milestone completed on 8 April 2026
SAC	[code for the actual service, with required number of digits]
Currency; value; taxable value	INR; ₹12,000; ₹12,000
Applicable GST rate for the service	[verified classification rate]; export supplied under LUT
IGST charged	₹0 — without payment under LUT
Invoice total	₹12,000
Reverse charge	No, for this assumed outward supply
LUT reference	[FY 2026–27 acknowledgement/reference]
Authentication	[authorised signature, unless an applicable electronic-invoice exception applies]

Include the mandatory export endorsement:

SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX

Use a consecutive invoice number, unique within the financial year and no longer than 16 characters. The SAC must describe your actual service. Zero tax charged under LUT does not make this a nil-rated or exempt service. CBIC: Rule 46 invoice particulars and endorsement.

Which date and currency should I use?

Use the actual issue date. For ordinary taxable services, Rule 47 generally allows 30 days from supply to issue the invoice; special and continuous-supply rules may affect timing. Check any applicable e-invoicing obligation before treating this skeleton as a complete invoice. CBIC: Rules 47–48.

An INR-denominated invoice does not mean every INR receipt qualifies as export realisation. Preserve evidence of convertible-foreign-exchange receipt or an RBI-permitted INR route. For foreign-currency invoices, retain both the invoice currency/value and the INR reporting value. Rule 34(2) uses the exchange rate determined under generally accepted accounting principles at the service’s time of supply; a later bank conversion can differ. CBIC: Rule 34(2).

Reconcile the invoice to returns and receipts

• GSTR-1: report the export invoice in Table 6A, without payment of tax. Do not fabricate a recipient GSTIN or shipping-bill details for a service export.
• GSTR-3B: reconcile the zero-rated outward value in Table 3.1(b).
• Statement 3: preserve invoice number, date and value, then match the separate receipt and FIRC/BRC records. A later receipt does not change the invoice date.

These reporting and evidence requirements are covered by the GST export-refund FAQ and GST return-comparison guidance. Continue with the Statement 3 worked example.

If you are buying a service from an overseas supplier, use the imported-service RCM and self-invoice guide. That is a different document from the sales invoice you issue here.