GST for Freelancers: Foreign Clients, Export of Services and LUT
Last checked · By Team FileMyGSTR· 5 min read
Key takeaways
- Freelancers must register for GST once aggregate turnover crosses ₹20 lakh (₹10 lakh in Manipur, Mizoram, Nagaland and Tripura), and foreign-client income counts.
- Work for overseas clients is an export of services, and a zero-rated supply, only if all five conditions in Section 2(6) of the IGST Act are met.
- File a Letter of Undertaking (LUT) in RFD-11 each financial year to export without paying IGST.
- Domestic clients are charged GST as usual, mostly at 18% for professional services.
- From 30 March 2026, intermediary services follow the general rule: the place of supply is where the client is.
On this page
Freelancers need GST registration only when their aggregate turnover crosses ₹20 lakh in a financial year (₹10 lakh in Manipur, Mizoram, Nagaland and Tripura). Income from foreign clients counts towards that limit. Once registered, work for overseas clients that meets the export conditions is a zero-rated supply: file a Letter of Undertaking (LUT) and you can invoice those clients without GST.
Does a freelancer need GST registration?
The rules are the same as for any service business:
- Below ₹20 lakh aggregate turnover: no registration needed, even if your clients are in other states or abroad. A specific exemption covers service providers making inter-state supplies below the threshold.
- Above ₹20 lakh: register within 30 days of crossing the limit.
- Aggregate turnover includes domestic fees, export income and exempt income, all counted on your PAN.
Example: A Pune-based UX designer earns ₹14 lakh from a US client and ₹9 lakh from Indian startups in 2026-27. Aggregate turnover is ₹23 lakh, which is above ₹20 lakh, so she must register, even though most of her income is export income that will carry no GST.
You can also register voluntarily below the limit. Freelancers often do this because Indian business clients want a GSTIN, or so they can claim back GST paid on laptops, software and co-working space. See our GST registration threshold guide for the full turnover rules.
When is freelance work an “export of services”?
Under Section 2(6) of the IGST Act, a supply is an export of services only if all of these are true:
- You (the supplier) are located in India.
- Your client (the recipient) is located outside India.
- The place of supply is outside India. For most freelance work this is where the client is located.
- You receive payment in convertible foreign exchange, or in Indian rupees where the Reserve Bank of India permits it.
- You and the client are not just different establishments of the same entity, such as your own branch abroad.
If any condition fails, the work is not an export and GST is charged as on a domestic supply.
What changed for intermediaries in 2026
Earlier, the place of supply for intermediary services (brokers and agents who arrange supplies between others, such as a sourcing agent for a foreign buyer) was the supplier’s location in India. Those services therefore didn’t count as exports. On the GST Council’s recommendation, the Finance Act 2026 omitted that special rule (Section 13(8)(b) of the IGST Act). From 30 March 2026, intermediary services follow the general rule: the place of supply is the client’s location. If you work as an agent or facilitator for foreign clients, ask a professional to look at your contracts. Older periods are still governed by the old rule.
What is a zero-rated supply?
A zero-rated supply is taxable, but at an effective rate of zero. Unlike an exempt supply, you keep your input tax credit (ITC), the GST you paid on business purchases that you can deduct or get refunded. You have two options:
| Option | How it works | Cash-flow impact |
|---|---|---|
| Export under LUT (most common) | Invoice without IGST, then claim a refund of unused ITC | No tax paid upfront |
| Export with payment of IGST | Charge and pay IGST, then claim a refund of that IGST | Money is blocked until the refund arrives |
Most freelancers use the LUT route.
How to file an LUT (RFD-11)
An LUT is valid for the whole financial year in which you file it, so file a new one each year before your first export.
- Log in to the GST portal.
- Go to Services > User Services > Furnish Letter of Undertaking (LUT).
- Select the financial year.
- Enter the name, address and occupation of two independent witnesses.
- Tick the self-declarations, then sign with DSC or EVC and submit.
Anyone who hasn’t been prosecuted for tax evasion of ₹2.5 crore or more can use an LUT.
Tip: Set a calendar reminder for 1 April. An export invoice raised before the new year’s LUT is filed may need IGST paid on it.
What goes on an export invoice?
Along with the usual fields in our GST invoice format guide, an export invoice should:
- show the client’s name and overseas address;
- carry the endorsement “Supply meant for export under LUT without payment of integrated tax” (or say IGST is paid, if you chose that route);
- state the amount in the foreign currency billed. Report the rupee value in your returns.
Which returns does a freelancer file?
- GSTR-1: report export invoices in the export section, and domestic invoices as B2B or B2C.
- GSTR-3B: export turnover goes in the zero-rated row. Domestic tax is paid here.
- If turnover is up to ₹5 crore, you can file quarterly under the QRMP scheme.
- Our guide on GSTR-1 vs GSTR-3B explains how the two link.
To recover GST paid on purchases, file a refund claim in RFD-01 for exports under LUT, generally within two years of the relevant date (for services, usually the date you receive payment).
Common mistakes
- Leaving export income out of turnover when checking the ₹20 lakh limit.
- Missing the annual LUT. Exporting without a valid LUT means IGST was payable.
- Treating a client’s Indian office as a foreign client. If the recipient is in India, it isn’t an export.
- Missing bank proof. Keep the bank’s foreign inward remittance advice, FIRC or e-FIRA for every receipt.
- Assuming the payment just has to arrive eventually. Proceeds must be realised within the period RBI allows. If they aren’t, refunds already received can be recovered.
- Charging the wrong tax to Indian clients. Same state: CGST + SGST. Different state: IGST. Most professional services are at 18%; check your SAC.
Watch out: Platform fees charged by foreign marketplaces or payment gateways may carry GST under reverse charge once you’re registered. See our reverse charge guide.
What to do next
- Total your income for the year, including foreign clients, and compare it with ₹20 lakh.
- If you’re registered or about to register, file this year’s LUT before your next foreign invoice.
- Set up an invoice template with the export endorsement.
If you’d like help getting registered and filing your LUT, our GST registration service covers both. For ongoing monthly or quarterly filings, see our GST return filing service.
Frequently asked questions
Do I need GST registration if all my clients are outside India?
Only if your aggregate turnover crosses the threshold (₹20 lakh in most states). Export income counts towards that limit, so a freelancer earning ₹25 lakh entirely from foreign clients must register.
Is GST charged on export of services?
Exports are zero-rated. If you file an LUT, you invoice the foreign client without GST. Without an LUT, you pay IGST and can claim it back as a refund.
How often do I need to file an LUT?
An LUT is valid for the financial year in which it is filed, so file a fresh one in RFD-11 on the GST portal before the first export of each financial year.
Does payment through PayPal or Payoneer count as foreign exchange?
It can, if the money reaches your Indian bank account in convertible foreign exchange (or in rupees where RBI permits). Keep the bank's inward remittance advice or FIRC as proof.
Can I claim a refund of GST paid on my laptop or software if I export under LUT?
Yes. Exports under LUT let you claim a refund of unused input tax credit by filing RFD-01, generally within two years of the relevant date.
Sources
- GST Portal: FAQs on furnishing Letter of Undertaking (FORM GST RFD-11)
- CBIC: GST – An Update (registration thresholds and inter-state services exemption)
- PIB: Recommendations of the 56th GST Council meeting
- Grant Thornton Bharat: Finance Act 2026 and intermediary services (omission of Section 13(8)(b) IGST Act)
- Tally: LUT filing guide for exporters (corroboration of annual validity)
Team FileMyGSTR
FileMyGSTR has helped small businesses and freelancers with GST, company and income tax compliance since 2017. Guides are checked against official CBIC, GST Council and GSTN sources on the date shown. This is general information, not advice for your specific case —talk to us if you're unsure.