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Short answer: For an Indian business seeking a refund of integrated tax paid on exported services, file FORM GST RFD-01 under Rule 89. Prepare an invoice statement showing invoice numbers and dates, and match the relevant Bank Realisation Certificates (BRCs) or Foreign Inward Remittance Certificates (FIRCs) to the claim. If services are exported without payment of integrated tax, verify the applicable Letter of Undertaking (LUT) or bond before filing.
Those documents do not, by themselves, prove that a transaction involving an overseas branch is an export of services. The contracting entities, branch status, recipient, place of supply, service facts and payment trail must be tested under the current IGST law. The checklist below separates that eligibility decision from the refund filing mechanics.
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What to establish before preparing a refund
An overseas-branch arrangement can involve several legal and accounting relationships: an Indian company, a foreign office, a foreign customer, inter-office work and one or more invoices. Start with a transaction map rather than assuming that calling an office a “branch” determines GST treatment.
Map the parties and establishments
- Identify the Indian GST-registered supplier that issued the invoice.
- Identify the contractual customer and the party that actually receives or uses the service.
- Describe the overseas branch’s legal status, ownership, registration and role. State whether it is part of the same legal entity or a separately incorporated establishment.
- Show which entity signed the contract, raised the invoice, performed each material function and received the consideration.
Keep an entity chart, contract, statements of work, invoices and inter-office agreements together. A branch label is a fact to document, not a conclusion on export eligibility.
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Check the export conditions under current law
Before choosing a refund route, have the current IGST Act and rules applied to the specific facts. The review should cover the recipient and establishment treatment, the place-of-supply provisions applicable to the service, whether consideration is received in the required manner, and whether the supplier and recipient relationship affects the export analysis. The official material available for this checklist does not decide those questions for any particular overseas-branch structure.
Make a written eligibility memo for each service category and period. Separate facts that are evidenced by contracts and remittance records from conclusions that require professional interpretation. A refund application should not be used to seek an indirect ruling on whether the underlying supply was an export.
Choose the correct refund route
The procedural route depends on whether integrated tax was paid on the exported service. Neither route cures a failure of the export conditions.
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1Repair Windows errors before they cause bigger problems2Scan for outdated or missing drivers - takes under a minute3Clear out junk files and repair common Windows errors| Tax/payment position | Application route | Core records | Critical caution |
|---|---|---|---|
| Integrated tax paid on exported services | FORM GST RFD-01 under Rule 89, as directed by Rule 96(9) | Invoice statement with numbers and dates; relevant BRC/FIRC records; return and tax-payment reconciliation | Do not use the shipping-bill deemed-application mechanism, which is the goods procedure. |
| Services exported without payment of integrated tax | Refund route under Rule 89 for the applicable claim, supported by a valid LUT or bond where required | LUT or bond covering the relevant period; invoice and remittance records; return and input-tax records required by the current form | Confirm the current undertaking, coverage and portal declarations before relying on this route. |
Rule 96(9) specifically sends integrated-tax refunds on exported services to RFD-01 and Rule 89. The shipping-bill shortcut associated with Rule 96 concerns exported goods, not a service invoice issued by an Indian business.
Document checklist for an overseas-branch services claim
Eligibility and transaction file
- Legal-entity and establishment chart identifying the Indian supplier, overseas branch and customer.
- Executed customer contract, purchase order or statement of work.
- Description of the service, delivery location, personnel or systems involved and the period of supply.
- Analysis of recipient, establishment and place-of-supply treatment under the current IGST provisions.
- Evidence explaining the overseas branch’s role and its relationship with the contracting parties.
Invoice schedule
Rule 89 calls for a statement containing invoice numbers and dates for the services covered by the refund. Build one controlled schedule rather than typing figures separately into working papers and the portal. Include, at minimum:
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- Invoice number and invoice date.
- Customer or recipient name and country.
- Service description and period.
- Taxable value, integrated-tax amount where tax was paid, and the refund period.
- Credit notes, cancellations, amendments or partial settlements affecting the invoice.
Use the same invoice numbering and dates in the GST returns, general ledger and refund application. Explain any difference before submission.
BRC and FIRC evidence
Collect the relevant Bank Realisation Certificates or Foreign Inward Remittance Certificates and map each certificate to the invoice or group of invoices it settles. A remittance file should show:
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- Amount and currency received.
- Remitter and beneficiary details.
- Bank reference or purpose code, where shown on the certificate.
- Exchange-rate or conversion basis used in the accounting and GST records.
- Any short payment, netting, advance, refund, set-off or multi-invoice allocation.
Where one remittance covers several invoices, prepare an allocation statement and retain the bank support used for that allocation. Where payment is pending, do not silently treat an invoice as realised; establish whether the current rule permits the particular claim and obtain advice where the timing is unusual.
LUT or bond file
CBIC guidance states that a registered person exporting services without payment of integrated tax must submit an LUT or bond. Retain the filed undertaking, acknowledgement and any prescribed supporting details. Verify that it was effective for the relevant period and covered the supplies in the claim. If the business changed its registration, constitution, signatories or export model, check whether a fresh undertaking or additional action was required.
An LUT or bond is a compliance instrument for the no-tax-payment route; it is not evidence that an overseas-branch supply satisfies every export condition.
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GST, accounting and remittance reconciliation
- Reconcile the invoice schedule to outward-supply returns for the same tax periods.
- For an integrated-tax-paid claim, reconcile the tax shown on invoices with the tax actually reported and paid.
- For a no-tax-payment claim, reconcile the relevant export invoices, LUT or bond and input-tax records required by the current refund calculation.
- Match the claimed period to ledger postings, foreign-currency receipts and bank certificates.
- Document credit notes, invoice amendments, advances and amounts carried into another period.
- Check that the refund amount is not claimed twice in another application or adjusted against a previous order.
The retrieved official material does not establish a special calculation formula for every overseas-branch fact pattern. Use the current Rule 89 formula, declarations and portal validations applicable on the filing date, and have a practitioner review unusual allocations.
How to file the service-export application
The GST portal labels and validations can change. Confirm the current form version and required declarations immediately before filing. The legal route for an integrated-tax-paid services refund remains RFD-01 under Rule 89.
- Freeze the claim period. Decide the tax period and list every invoice, credit note and remittance included. Do not mix periods merely because one bank receipt settles invoices from several months.
- Complete the eligibility review. Approve the entity chart, contract analysis, recipient and place-of-supply treatment, and payment evidence before entering a refund amount.
- Select the services refund category. For integrated tax paid on exported services, use the RFD-01 route required by Rule 96(9) and Rule 89. Do not select a goods shipping-bill mechanism.
- Enter the invoice statement. Upload or enter invoice numbers and dates exactly as they appear in the GST records. Include the tax and value fields requested by the current form.
- Attach or retain remittance support. Provide the relevant BRC/FIRC information and the invoice-to-certificate reconciliation. Follow the portal’s current file-size, format and declaration requirements.
- Attach the LUT or bond evidence when using the no-tax-payment route. Confirm the undertaking’s period and applicability; do not substitute an expired or unrelated acknowledgement.
- Run an internal four-way check. Compare the draft application with the invoice register, GST returns, ledger and bank file. Resolve every difference or record a defensible explanation.
- Submit and preserve the complete record. Save the ARN, filed form, uploaded schedules, acknowledgements, declarations and all correspondence. Monitor notices and respond with the same invoice-level reconciliation.
Overseas branch issues that need separate analysis
Same entity does not automatically mean export
An overseas branch may be an establishment of the Indian legal entity rather than an independent customer. That relationship can affect the recipient and establishment analysis. Conversely, a foreign company or customer may contract separately with the Indian GST registration while the branch performs work. The contract, invoice flow and actual service arrangement must be examined together.
Do not transplant the domestic-branch clarification
CBIC Circular 199/11/2023-GST, dated 17 July 2023, discusses services between offices in different Indian States treated as distinct persons. It is useful context for why office relationships and registrations matter, but it does not decide whether a particular overseas branch is a qualifying recipient or establishment for export purposes. Cite it only for the domestic-office issue it addresses.
Payment evidence is not a substitute for legal eligibility
A bank certificate can show that money entered India, but it does not prove the recipient, place of supply or character of the service. Keep remittance evidence and the legal eligibility analysis as separate parts of the file.
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Common failure points and corrective actions
Using the goods procedure
Symptom: The applicant expects a shipping bill to act as the refund application for an exported service. Correction: Use RFD-01 under Rule 89 for the service-export integrated-tax refund route.
Invoice and bank records do not reconcile
Symptom: A BRC/FIRC total differs from the invoices in the claim because of exchange-rate movements, bank charges, netting or multi-invoice receipts. Correction: Prepare an allocation schedule, explain the difference and retain the bank documents supporting the treatment.
LUT coverage is unclear
Symptom: The business has an acknowledgement but cannot show that the LUT or bond covered the claim period or supplies. Correction: Verify the effective period and registration details, then obtain current professional guidance before filing.
Branch status is assumed rather than documented
Symptom: The file relies on the word “branch” without an entity chart or contract analysis. Correction: Document ownership, registrations, contracting parties, service performance and recipient treatment before claiming that the supply is exported.
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Symptom: A checklist follows the older master refund guidance without checking amendments or portal changes. Correction: Use Circular 125/44/2019-GST only as historical context and confirm the current rules, form fields and CBIC instructions at submission.
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Retention and audit readiness
Keep a period-indexed folder containing the approved eligibility memo, entity chart, contracts, invoices, credit notes, BRCs/FIRCs, LUT or bond, GST returns, ledger extracts, bank reconciliation, filed RFD-01 and ARN. Add every notice, reply, clarification and refund order. The person who prepared the bank allocation should be able to reproduce it from the retained evidence without relying on an email inbox or a spreadsheet with unexplained overrides.
For recurring services, maintain a change log. A new customer contract, service line, branch registration, invoicing entity, payment route or place-of-supply fact can require a fresh eligibility review even when the prior period was accepted.
When to obtain a fact-specific GST opinion
Obtain current Indian GST advice before filing if the overseas branch is part of the same legal entity, the recipient and performer are different establishments, consideration is received through netting or inter-office entries, payment falls outside the ordinary remittance pattern, or the place-of-supply rule is uncertain. Provide the adviser with the entity chart, contracts, service description, invoice flow, branch documents, GST returns and foreign-remittance evidence. A professional can then confirm both export eligibility and the appropriate refund route instead of merely checking whether attachments exist.
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Bottom line
Build the claim in two layers. First, prove from the current IGST rules and the business’s facts that the overseas-branch transaction qualifies as an export of services. Second, for the eligible period, file the correct Rule 89 application: RFD-01 for integrated tax paid, with the required invoice statement and matched BRC/FIRC evidence, or the applicable no-tax-payment route with a valid LUT or bond. The documents support a refund claim; they do not create entitlement where the underlying export conditions are unresolved.
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