LUT (Letter of Undertaking) Filing

A Letter of Undertaking (LUT) lets a GST-registered exporter ship goods or services without paying IGST upfront. Instead of paying tax and waiting for a refund, you file an LUT and export at a zero rate, keeping your working capital free. The LUT is filed online on the GST portal in Form GST RFD-11, is free, and is approved almost automatically for eligible exporters. It must be filed afresh for each financial year. Samkhya files your LUT and manages your export GST compliance.

LUT Filing: A Detailed Guide

Exports are zero-rated under GST, which can be claimed in two ways: by paying IGST on the export and claiming a refund, or by filing a Letter of Undertaking and exporting without paying IGST at all. The LUT route is preferred because it does not lock up working capital in refund claims. An LUT is filed online in Form GST RFD-11 before the start of, or early in, each financial year, and a single LUT covers all of that year’s exports. By filing it, the exporter undertakes to export within the prescribed time and to receive payment in convertible foreign exchange, in line with Rule 96A. Any GST-registered exporter can file an LUT, except those prosecuted for tax evasion exceeding Rs. 2.5 crore, who must instead furnish a bond with a bank guarantee.

Advantages of Filing an LUT

Filing an LUT offers clear advantages:

  • No IGST Blockage: Export without paying IGST upfront, so no working capital is tied up.
  • Better Cash Flow: Avoid the 60 to 90 day wait that an IGST refund can take.
  • Simple Online Filing: The LUT is filed entirely online on the GST portal, with no documents to upload.
  • Free and Automatic: There is no fee, and approval is almost automatic for eligible exporters.
  • One Filing per Year: A single LUT covers all exports for the financial year.
  • For Goods and Services: It applies to both export of goods and export of services.

Points to Keep in Mind

A few conditions apply to an LUT:

  • Annual Filing: A fresh LUT must be filed for each financial year, ideally before the first export invoice.
  • Eligibility Bar: Exporters prosecuted for tax evasion above Rs. 2.5 crore cannot use an LUT and must furnish a bond.
  • Export Time Limit: Goods must be exported within three months of the invoice, and foreign exchange realised within the prescribed period.
  • Conditions Apply: Failure to meet Rule 96A conditions can trigger IGST with interest.
  • GST Registration Needed: Only a GST-registered exporter can file an LUT.
  • Witnesses Required: The details of two witnesses are entered in the form.

When You Need an LUT

An LUT is useful in these situations:

  • You export goods from India and want to avoid paying IGST upfront.
  • You export services such as software, consulting, or freelancing to overseas clients.
  • You supply to a Special Economic Zone unit or developer.
  • You want zero-rated supplies without blocking working capital in refunds.
  • You are a GST-registered exporter eligible to furnish an LUT.

Eligibility Criteria

Eligibility to file an LUT is as follows:

  • Any person registered under GST who exports goods or services can file an LUT.
  • The exporter must not have been prosecuted for tax evasion exceeding Rs. 2.5 crore.
  • Those who are ineligible can instead furnish a bond with a bank guarantee in Form RFD-11A.
  • The exporter must commit to export and foreign-exchange realisation within the prescribed time.
  • A valid GST registration and an authorised signatory are required.

The LUT Filing Process

The LUT is filed online on the GST portal under the exporter’s GSTIN, in Form GST RFD-11, with no physical documents required. The exporter selects the financial year, ticks the three undertakings on the form (to export within the prescribed time, to comply with GST provisions, and to pay IGST with interest if the conditions are not met), enters the details of two witnesses, and submits the form using a Digital Signature Certificate or EVC. Acceptance is generated on the portal automatically for eligible exporters, and an acknowledgement with the application reference number can be downloaded. The accepted LUT is then quoted on export invoices with the declaration that the supply is made under LUT without payment of IGST.

Documents and Details Required

Since the LUT is filed online with nothing to upload, you mainly need the details ready:

  • The GST registration certificate and GSTIN, and the PAN of the business.
  • The authorised signatory’s details and a Digital Signature Certificate or EVC access.
  • The names, occupations, and addresses of two witnesses (the previous year’s LUT can be referenced but is not mandatory).

LUT Filing Process

Filing an LUT follows a quick sequence:

  1. Log in to the GST portal with your GSTIN.
  2. Go to Services and select the Letter of Undertaking (RFD-11) option.
  3. Choose the financial year for which the LUT is being filed.
  4. Tick the three undertakings on the form.
  5. Enter the details of two witnesses.
  6. Sign and submit using a Digital Signature Certificate or EVC.
  7. Download the acknowledgement and quote the LUT on export invoices.

File your LUT with Samkhya

Filing your LUT with Samkhya Corporate Services is simple. Just follow these easy steps:

  • Share your GST details: Tell us your GSTIN and export activity.
  • We prepare the undertaking: We complete the RFD-11 with the required declarations.
  • Fill the form: Provide your authorised signatory and witness details.

From there, our team files the LUT and supports your export invoicing and returns.

After Filing the LUT

Keep your LUT compliant through the year:

  • Quote the LUT: Mention the LUT and the no-IGST declaration on every export invoice.
  • Export in Time: Export goods within three months of the invoice date.
  • Realise Proceeds: Receive export payment in convertible foreign exchange within the prescribed period.
  • File GST Returns: Report exports correctly in GSTR-1 and GSTR-3B.
  • Renew Annually: File a fresh LUT for the next financial year before exporting.
  • Keep Records: Retain shipping and banking documents that evidence the exports.

How an LUT Saves Tax and Cash

Under GST, exports are zero-rated, meaning no GST is ultimately payable on them. Without an LUT, an exporter must pay IGST on each export invoice and then claim it back as a refund, which can take 60 to 90 days and ties up working capital. By filing an LUT, the exporter is allowed to make the supply without charging or paying IGST at all, so there is no tax to recover and cash flow stays free. The exporter can still claim a refund of accumulated input tax credit on the inputs used for those zero-rated supplies. The LUT itself is free and involves no tax cost; it is simply the mechanism that delivers the zero-rating up front. If the export conditions under Rule 96A are not met, the unpaid IGST becomes payable with interest.

LUT vs IGST Refund Route

Feature Export under LUT Export with IGST + Refund
IGST on Export Not paid. Paid, then refunded.
Working Capital Stays free. Locked until refund.
Refund Wait Not applicable. Typically 60 to 90 days.
Filing One LUT per financial year. A refund claim per export.
Input Tax Credit Refund of accumulated ITC. IGST refunded; ITC as usual.
Best For Regular exporters. Occasional or ineligible exporters.

Frequently Asked Questions

What is an LUT?

A Letter of Undertaking is a declaration filed by a GST-registered exporter that lets them export goods or services without paying IGST upfront, keeping working capital free.

How is an LUT filed?

It is filed online on the GST portal in Form GST RFD-11, with no documents to upload, and is approved almost automatically for eligible exporters.

How often must an LUT be filed?

A fresh LUT must be filed for each financial year, ideally before raising the first export invoice of that year.

Who is not eligible to file an LUT?

Exporters who have been prosecuted for tax evasion exceeding Rs. 2.5 crore cannot file an LUT and must furnish a bond with a bank guarantee instead.

What happens without an LUT?

Without an LUT you must pay IGST on each export and claim a refund later, which can take 60 to 90 days and blocks working capital.

Does an LUT apply to service exporters?

Yes. Software developers, consultants, freelancers, and other service exporters use an LUT to invoice overseas clients without charging IGST.