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GST LUT Form
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GST LUT Form

Overview

What is a GST LUT Form?

A Letter of Undertaking (LUT), filed in Form GST RFD-11 under Rule 96A of the CGST Rules, 2017, is a formal, self-declared undertaking that lets a registered exporter supply goods or services outside India, or to a Special Economic Zone (SEZ), without paying Integrated GST (IGST) upfront. Under Section 16 of the Integrated Goods and Services Tax Act, 2017, exports and supplies to SEZs are treated as 'zero-rated supplies' — meaning no tax is ultimately meant to be borne on them.

Guide to GST LUT Form (Letter of Undertaking)

Salient Features, Documentation Requirements, Filing Pipeline, and Compliance Rules

1. Introduction

A Letter of Undertaking (LUT), filed in Form GST RFD-11 under Rule 96A of the CGST Rules, 2017, is a formal, self-declared undertaking that lets a registered exporter supply goods or services outside India, or to a Special Economic Zone (SEZ), without paying Integrated GST (IGST) upfront. Under Section 16 of the Integrated Goods and Services Tax Act, 2017, exports and supplies to SEZs are treated as 'zero-rated supplies' — meaning no tax is ultimately meant to be borne on them.

Without an active LUT (or, alternatively, a manual export bond), an exporter would be forced to pay full IGST out-of-pocket on every outbound invoice and then separately apply for a tax refund. This slow administrative recovery loop frequently locks up critical corporate working capital for months at a time.

The LUT framework was introduced as a simpler substitute for the earlier mandatory export bond through Notification No. 37/2017-Central Tax dated 4 October 2017. The entire application pipeline is managed completely online via the common GST portal, generating an instantaneous automatic acknowledgment with no routine departmental approval required.

2. Salient Features

Zero-Rated Exports Without Upfront Tax The core mechanism of an LUT is allowing exporters to clear shipments and issue foreign service invoices without paying IGST at the point of supply. This directly guards corporate working capital from getting tied up in standard government tax refund processing queues.
Standardized Form Submission (GST RFD-11) The digital undertaking is declared and transmitted via Form GST RFD-11 within the taxpayer's authenticated services dashboard, establishing a clean, uniform system for legal declarations across all Indian trade zones.
Annual Financial Year Validity Window An approved LUT is not permanently active; it remains valid strictly for the single Financial Year (FY) in which it is submitted. Exporters must file a fresh renewal application at the start of each new financial year (typically available prior to April 1st) to ensure uninterrupted zero-rated processing.
Broad Eligibility Guidelines Virtually all registered GST exporters qualify for the LUT system, provided they have not been prosecuted for tax evasion offenses where the tax amount involved exceeds ₹250 Lakhs (₹2.5 Crore) under the Act. Taxpayers who fail this condition must instead provide a physical export bond backed by a bank guarantee.
Mandatory Witness Validation The online form requires the legal identification details (names, occupations, and contact addresses) of exactly two independent witnesses to validate the integrity of the exporter's binding declaration.

3. Required Information and Documentation

Because the LUT operates via automated digital self-declaration, physical document scans are generally not required at the time of filing. Instead, specific structured data inputs must be prepared:

Data Category Required Details & Validation Fields
3.1 Primary Signatory Details • Name and designation of the Managing Director, Partner, or Authorised Signatory.
• Active Digital Signature Certificate (DSC) or Electronic Verification Code (EVC) link tied to the user profile.
• Valid corporate resolution or letter of authorisation confirming signing rights (kept on record).
3.2 Witness Attestations • Complete names, residential/office addresses, and professional occupations for two independent witnesses.
• The system requires these inputs directly within the online Form GST RFD-11 grid columns.
3.3 Prior Year References • If renewing, the system requests the previous year's Application Reference Number (ARN).
• While not mandatory to upload the old receipt, referencing the history maintains continuity across filing periods.
3.4 Bank / Bond Documents
(Exception Basis Only)
• Required only if the taxpayer fails the prosecution threshold test.
• Requires manual execution of a physical bank bond along with a 15% bank guarantee backing the calculated tax risk.

4. The Online LUT Filing & Compliance Process

Step 1: Dashboard Navigation & FY Selection

Log into the official GST common portal (www.gst.gov.in). Navigate to Services > User Services > Furnish Letter of Undertaking (LUT). Select the appropriate Financial Year from the drop-down selector menu for which the zero-rated export permissions are required.

Step 2: Legal Declarations and Witness Entry

The interface displays Form GST RFD-11 alongside three critical self-declaration check-boxes. These confirm that the exporter will export goods/services within legal deadlines and fulfill all compliance rules. The user must select all checkboxes and enter the names, addresses, and occupations of two independent witnesses.

Step 3: Place Definition and Digital Authentication

Enter the current filing location (Place field), select the authorised signatory profile from the system drop-down, and sign the form using a Class 3 Digital Signature Certificate (DSC) for corporate entities/LLPs, or an Electronic Verification Code (EVC) OTP for proprietorships.

Step 4: Immediate ARN Generation and Record Retention

Upon successful signature transmission, the network instantly generates an Application Reference Number (ARN) and creates a downloadable PDF acknowledgment receipt. This file serves as your official legal proof of LUT filing. The ARN should be noted and retained for custom clearances, export shipping bills, and service refund logs.

Critical Compliance Deadlines & Consequences
Goods Export Deadline: The physical goods must be exported out of India within three months from the date the tax invoice is issued. If this deadline is missed, the exporter must pay the applicable IGST plus 18% annual interest within 15 days, or the LUT facility will be temporarily suspended.
Services Realisation Window: Foreign exchange payments for exported services must be successfully realised in convertible foreign exchange (or permissible INR) within one year from the invoice date. Failing this triggers the same requirement to pay tax plus interest.

5. Frequently Asked Questions (FAQs)

Collapsible FAQs (or accordions) let visitors browse questions and click to expand answers, keeping pages uncluttered

What happens to the zero-rated status if goods are not exported within 3 months? +
If a taxpayer fails to export the goods within three months of the invoice date, the tax exemption under the LUT is paused for that transaction. The exporter must pay the full applicable IGST along with 18% annual interest within 15 days. If they fail to clear this payment, the entire LUT facility is suspended across the portal until the dues are settled.
Is the realisation timeline different for the export of services? +
Yes. For the export of services, the payment must be received in convertible foreign exchange (or INR where permitted by RBI) within one year from the invoice date, or within the time allowed under FEMA rules (currently 15 months as per RBI guidelines), whichever is later. This is longer than the three-month window required for physical goods.
Can a single LUT be used for exports across multiple GST registrations? +
No. An LUT is filed and applies strictly at the individual GSTIN level. If a business operates through multiple state-level GST registrations under the same PAN, it must submit a separate Form GST RFD-11 application for each individual GSTIN from which zero-rated supplies are made.
Who can act as a witness for the LUT application form? +
The form requires two independent, reliable witnesses. Their names, full addresses, and occupations must be entered directly into the dashboard fields. To ensure compliance, these witnesses should be independent individuals who do not have a direct financial or management stake in the exporting business.
What proof of filing does an exporter receive or retain? +
The platform does not issue a standalone certificate with a unique number. Instead, the Application Reference Number (ARN) and the downloadable PDF acknowledgment receipt serve as your official legal proof of filing for that financial year. This ARN should be printed and kept on file for customs paperwork, port clearings, and tax audits.


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