Paid through Upwork, PayPal, Stripe or AdSense: export of services and refund records

Income you receive through a platform can be an export of services, supplied under LUT without IGST, when the person who pays for your service is outside India and the other export conditions are met. The platform’s name on your bank credit does not settle that. Check who your contract is with, then collect the remittance document your payment provider issues. IGST Act, sections 2(6) and 13(2).

This guide is for GST-registered freelancers, creators and studios. For a direct contract with a foreign business, use the foreign-client invoice guide; for App Store sales, use the App Store guide.

Find your customer in the platform’s terms

For most services, the place of supply is the location of the recipient. Where consideration is payable, the recipient is the person liable to pay it. IGST Act, section 13(2); CGST Act, section 2(93). A marketplace that only connects you with clients and collects their money is not your customer. A platform that buys your service is.

Platform	Who the terms make your contracting party	What to check
Upwork	The client. A service contract “is a contractual relationship directly between the Client and the Freelancer”, and Upwork “is not a party”. Upwork’s escrow company collects the client’s payment as your agent. Upwork User Agreement	Each client’s location. A client in India makes that contract a domestic supply
Fiverr	The buyer. “Orders are the formal agreements between a Buyer and Seller.” Fiverr Terms of Service	Each buyer’s location
Google AdSense	Google Asia Pacific Pte. Ltd., Singapore, under the AdSense terms Google applies to India. AdSense Terms of Service for India	The terms version you accepted, in your AdSense account
YouTube Partner Programme	YouTube’s Terms of Service for India name Google LLC as the provider of the service, and say Partner Programme payments are treated as royalties. YouTube Terms of Service The Partner Programme agreement itself is in YouTube Studio under Settings → Agreements. YouTube Help	Open your agreement and record the contracting entity and its address
Stripe, PayPal, Payoneer, Skydo, Wise	Payment services that collect or transfer the money, not your customer	The customer who paid through them

We found no advance ruling or court order on whether AdSense or YouTube income of an Indian publisher is an export of services. Start from the entity named in your own agreement, and have your CA record the decision with the agreement attached.

The AdSense terms also say payments to you “will be treated as inclusive of tax (if applicable) and will not be adjusted”. Google does not add GST to the payout, so if you supply without an LUT and pay IGST, that tax comes out of the amount you receive.

Check the payment condition

An export of services needs payment in convertible foreign exchange, or in Indian rupees where RBI permits. IGST Act, section 2(6)(iv). Most providers credit your Indian account in rupees after converting your customer’s payment.

The Madras High Court held that a service exporter whose customers paid PayPal in US dollars, with Citibank crediting rupees to the exporter, had exported its services: “Merely because the receipts are rooted through the intermediary and received in Indian currency ipso facto would not mean that the petitioner has not exported services”. It allowed the refund. Afortune Trading Research Lab LLP, 16 February 2024, paragraph 41.

CBIC’s LUT circular also says an LUT is available for supplies to countries outside India “irrespective of whether the payments are made in Indian currency or convertible foreign exchange as long as they are in accordance with the applicable RBI guidelines”. Circular 88/07/2019-GST, amended paragraph 2(k).

The GST Council recommended on 8 October 2026 a circular clarifying receipts in foreign exchange or rupees for exports. As of 22 October 2026 it has not been issued. GST Council press release, paragraph 10.

Get the remittance document from your provider

Statement 3 needs a bank realisation or remittance certificate reference for each receipt. Each provider issues a different document:

Provider	Document	How to get it
PayPal	A free weekly digital Foreign Inward Remittance Advice (FIRA) from February 2026; monthly before that. A custom FIRA through Citibank for a fee	Reports → Tax → Foreign Inward Remittance Advise (FIRA) → Download in your PayPal business account. PayPal India
Payoneer	A free digital FIRA for each payment. Payoneer says only your own bank can report the receipt to RBI’s EDPMS and issue an e-FIRA, using that PDF	Payoneer delivers it automatically. Payoneer FAQ
Stripe India	A payment advice from Standard Chartered Bank for each export payout	Emailed to your registered Stripe address the day the payout is processed. Stripe docs
Upwork	A no-objection certificate (NOC) for a Bank Inward Remittance Certificate (BIRC) from the payment processor. Upwork says it is “not a bank and do[es] not produce the FIRC”; your bank uses the NOC to issue its FIRC or FIRA	Request it from Upwork; it usually arrives within four weeks. Upwork Help
Google AdSense	A payment receipt for each payment. Google’s help pages do not mention a FIRC	Payments → Payments info → View transactions, then the payment’s link. AdSense Help. Ask your bank for its certificate for the credit

If the document your provider gives describes itself as an advice rather than a certificate, ask the bank that received the money whether it can issue its own certificate for the credit. In the Madras High Court case, the lower authority had rejected a Citibank document marked as an advice and not a FIRC. The Kerala High Court has since held that an officer should not reject a bank’s “advice of foreign inward remittance” because of its title, without examining its contents. ABE Service, 10 July 2026, paragraph 10. For Wise and receipts direct to your bank, and for DGFT’s eBRC, see FIRC and bank evidence for a refund.

CA Himank Singla advises Upwork freelancers to keep the FIRCs, invoices, Upwork statements and bank credits together for refund claims and scrutiny.

Platform fees: reverse charge and refundable credit

Upwork charges 18% GST on its service, membership and Connects fees, unless you add your GSTIN to your Upwork tax information, in which case it stops collecting the tax. Upwork Help: India GST for freelancers.

A service from a supplier outside India to a registered business in India is taxed under reverse charge: you pay IGST on the fee in cash and take the input tax credit (ITC) where it is eligible. Notification 10/2017-Integrated Tax (Rate), entry 1. Upwork’s page does not mention reverse charge. Check each platform’s invoice for who charged the fee and whether tax was charged on it.

That ITC counts towards the Net ITC in your export refund, with your other purchases, such as software subscriptions. CA Pratik Bharda described a UI designer billing US clients through Stripe under an LUT, with ₹6.8 lakh of accumulated credit from a laptop, software subscriptions and office rent. Use the imported-service RCM guide to record the fee.

Because Upwork charges its fee to you as a separate service, the amount the client pays under the contract is the starting point for your export invoice, and the fee is your purchase. Keep the platform statement showing the gross amount, fees and any withholding, and have your preparer confirm the invoice value.

FEMA reporting through your bank

From 1 October 2026, RBI’s export regulations ask exporters of services to declare their invoices to their bank each month. At its press conference on 7 October 2026, RBI said individuals providing services under contracts of a personal nature do not need to report, but it has not yet published the FAQs it promised. See the Export Declaration Form for service exports.

Records for each platform invoice

• The terms or agreement that names your customer, with the version date.
• Your export invoice to that customer, under LUT.
• The platform statement showing the gross amount, fees and any tax withheld.
• The provider’s remittance document and the bank’s certificate, if it issues one.
• The bank credit for the amount received.

Carry these into Statement 3 with the Statement 3 worked example, which shows how one payout that settles several invoices is allocated.