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Export & Place of Supply Documentation Checklist — GST

The zero-rated-supply conditions for export of goods and the four-part test for export of services under Section 2(6) of the IGST Act, plus the place-of-supply rules that decide whether a supply is even export in the first place.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Basis
Section 2(6), IGST Act 2017 (export of services)
Test
All 4 conditions must be met — one failure defeats export treatment
Common trap
Intermediary services — place of supply is the SUPPLIER's location
Format
Microsoft Word (.docx)
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EXPORT & PLACE OF SUPPLY DOCUMENTATION CHECKLIST

Entity: ___ · GSTIN: ___ · Financial year ended: ___

A. Export of goods — zero-rated supply conditions

  • Goods physically taken out of India, or supplied to a SEZ unit/developer for authorised operations.
  • Shipping bill / bill of export filed and goods actually exported — the shipping bill is treated as the export application (LUT/bond reference) and refund claim (for the applicable category) both.
  • Export made either under a Letter of Undertaking (LUT) without payment of integrated tax, or with payment of IGST followed by refund — the entity's choice for the year should be documented and consistently applied.
  • Where exported under LUT, the LUT (Form GST RFD-11) was valid and in force for the relevant tax period — a lapsed or not-yet-renewed LUT invalidates the without-payment route for supplies made after expiry.
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Common questions

FAQs.

Why does a service with all payment received in foreign exchange sometimes NOT qualify as an export?
Because Section 2(6) requires all five conditions together, not just foreign-exchange receipt — the most common failure points are the place-of-supply test (e.g. intermediary services are deemed supplied at the supplier's own location, defeating export treatment even with foreign exchange receipt) and the "distinct persons" exclusion, where the supplier and recipient are establishments of the same legal entity (e.g. an Indian branch invoicing its own foreign head office) rather than genuinely separate parties.
What is an "intermediary" for place-of-supply purposes, and why does it matter so much?
An intermediary arranges or facilitates a supply between two other parties without supplying it on their own account (e.g. a broker or agent), as distinct from someone who supplies the underlying service on their own account. The place of supply for an intermediary's OWN service is the intermediary's location, not the recipient's — so an Indian company genuinely acting as an intermediary for an offshore client is usually NOT making an export of services, however it invoices or receives payment.
What documentation supports export-of-goods zero-rating on audit?
The shipping bill/bill of export (filed electronically and linked to the GST return), the LUT (if exported without IGST payment) valid for the relevant period, the export invoice, and — for services — the Bank Realisation Certificate / FIRC evidencing receipt of consideration in convertible foreign exchange. Missing or lapsed LUT for even part of the year is a common finding that converts what should have been a without-payment export into a liability for that period.
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