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Indian clinical research organisations (CROs) should keep an engagement-level file that connects the overseas contract and services performed to the export invoice, payment receipt, GST returns, refund calculation and input tax credit (ITC) claimed. For exports made without payment of IGST, include the filed Letter of Undertaking (LUT) or bond. The contract and actual service model also need to support the export-of-services conditions; an overseas client alone does not establish eligibility.
Build a document file for each engagement
Keep records that let you trace the transaction from the agreed work through delivery, billing, receipt and the GST claim. Some items below are expressly reflected in GST rules or refund requirements; others are prudent evidence to substantiate the transaction and reconcile the claim. This is a practical recordkeeping checklist, not a claim that every supporting item must be attached to every refund application.
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Contract and evidence of services performed
- Signed master services agreement, statements of work, amendments, purchase or work orders, and milestone schedules.
- Deliverables, client approvals or acceptance, and material correspondence showing the work requested, performed and delivered.
- Records identifying the contracting parties, the recipient of the service, the scope of work and the service arrangement in practice.
These records help establish what the CRO supplied and to whom. They are particularly useful when the CRO’s role, recipient or place of supply is not apparent from the invoice alone.
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Retain copies and sequential invoice records. Export invoices should carry the applicable endorsement:
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- “SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGST” for the route where IGST is paid.
- “SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST” for the no-IGST route.
The invoice rules require recipient name and address, delivery address, and destination country particulars. The general deadline for issuing a service invoice is 30 days from the date of supply, subject to specified exceptions. Check the applicable rule for the transaction rather than assuming the general deadline covers every case.
LUT or bond for the no-IGST route
If exporting without payment of IGST, keep the relevant FORM GST RFD-11 LUT or bond and its filing acknowledgement. Rule 96A requires the LUT or bond to be furnished before making the export supply under this route.
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For exported services under Rule 96A, monitor whether payment is received in convertible foreign exchange, or in Indian rupees where the Reserve Bank of India permits, within one year from the invoice date. The rule allows a further period where permitted; failure to meet the applicable period can lead to tax and interest consequences.
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Keep Bank Realisation Certificate (BRC) or Foreign Inward Remittance Certificate (FIRC) evidence and link each receipt to the relevant invoice. Your records should make it possible to identify the invoice number and date, amount and currency received, and receipt date.
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Also retain bank advice and remittance records explaining grouped or split payments, bank charges, deductions, advance receipts and exchange conversion. These supporting records help reconcile a bank receipt that does not match an invoice amount one-for-one. Refund rules call for invoice details together with relevant BRC/FIRC information for export-of-services claims.
Returns and refund claim records
- GSTR-1 filing details and relevant return acknowledgements.
- The RFD-01 refund application, its schedules, invoice-wise export statement and refund calculation.
- Notices and responses, and any sanction or deficiency orders relating to the claim.
GST Portal guidance allows export invoices to be reported in GSTR-1 before shipping-bill details are available, with those details added by amendment in a later period. Keep the filing and amendment evidence that applies to your return.
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Accounts, source documents and ITC support
Maintain sales, tax, input-tax and ITC accounts; inward tax invoices; credit and debit notes; and a reconciliation connecting eligible ITC to the refund claimed. CBIC recordkeeping rules for service suppliers call for accounts of input services used and services supplied, and for audit-trail links between source documents and financial accounts.
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Under the export-of-services test described in CBIC sectoral FAQs, all of these conditions must be met:
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- The supplier is located in India.
- The recipient is located outside India.
- The place of supply is outside India.
- Consideration is received in convertible foreign exchange, or in Indian rupees where the RBI permits.
- The supplier and recipient are not merely establishments of the same person.
Keep contract and service-delivery evidence that supports these facts. Do not rely only on the client’s overseas address or the CRO service label: the recipient, place of supply and actual roles in the arrangement matter.
Review the CRO’s role in the transaction
Assess who supplies what service to whom, whether the CRO contracts as principal or arranges a supply between other parties, and how the recipient and place of supply are determined. These facts can affect whether export treatment is available, including where an intermediary issue arises. A CRO-specific conclusion cannot be drawn without reviewing the operative agreements and service workflow.
Choose and document the applicable zero-rating route
The GST Portal describes two general routes for zero-rated supplies. The evidence and refund calculation depend on which route is used; confirm eligibility and current requirements for the particular claim.
| Route | IGST treatment | Refund sought | Records to connect |
|---|---|---|---|
| Export without payment of IGST | No IGST paid on the export supply; retain the prior-filed LUT or bond. | Eligible unutilized ITC, subject to applicable rules. | LUT or bond, export invoices and return details, ITC records, and the refund calculation and supporting records. |
| Export on payment of IGST | IGST paid on the export supply. | Refund of tax paid, subject to applicable rules and restrictions. | Export invoices, return and payment records, and the refund claim records applicable to this route. |
Reconcile refund turnover to the right period
For an export-of-services refund, the refund rules require an invoice-and-BRC/FIRC statement. For the unutilized-ITC route, export turnover of services is defined with reference to payments received during the relevant period, services completed during that period for which an advance was received earlier, and advances received for services not completed during that period.
Accordingly, an export invoice by itself does not establish that its full value belongs in the same refund period. Reconcile the claim calculation to receipts, service completion, GST returns and ledgers, and retain the workpapers showing how amounts were assigned to the period.
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