India → world · export of services

The Freelancer's Export Compliance Playbook

Everything an Indian freelancer needs to bill global clients confidently and stay fully compliant at home. Four rulebooks, one page, no jargon we don't explain.

Anchored in RBI Master Direction 16/2015-16 · updated Aug 2026
Pillar 1 · Banking

Every foreign payment is a regulated export.

RBI and FEMA don't care what you do for a living. They care how the money arrived, what it was tagged as, and how fast it landed.

9months

To bring each invoice's money into India, counted from the invoice date. The single hardest deadline. Delays need a bank-routed extension.

6+years

How long to keep invoices, contracts, credit advices and e-FIRAs — your defence file in any FEMA or tax review.

100%of forex

Can sit in an EEFC account without instant conversion — but unused funds must convert to INR by end of the next month.

Channels

Authorised pipes only

AD Category-I banks or RBI-approved platforms (Wise, Payoneer, PayPal and peers). No RBI approval needed — just the right pipe.

Purpose codes

Tag every remittance

P0802 software · P0806 information services · P0803 / P0807 consulting · P1001 creative. The code drives your bank's reporting — and yours.

Proof

FIRC / e-FIRA per payment

Your proof of foreign-exchange receipt. GST zero-rating, refunds and audits all lean on it. Collect and file every one.

SOFTEX & EDF

Declare the export

SOFTEX applies mainly to STPI/SEZ-routed software exports. The newer EDF requirement asks service exporters to declare invoices so inward money can be matched and closed in EDPMS.

Pillar 2 · GST

Exports of services are zero-rated.

Zero-rated is not exempt. You charge no GST, but you still register once liable, file, and report every export rupee.

All five must hold

When is it an export?

You're in India · client is outside India · place of supply is outside India · payment arrives in convertible forex (FIRC is proof) · you and the client aren't branches of one entity.

Preferred · Route A

Export under LUT

File Form RFD-11 once a year on the GST portal, then invoice foreign clients at 0% IGST. No tax paid upfront, no cash stuck.

Route B

Pay IGST, claim refund

Charge 18%, recover it later. Legal — but it parks your working capital with the department while you wait.

Threshold

Register at ₹20 lakh

Aggregate turnover — exports count. ₹10 lakh in special-category states. Below it, voluntary registration unlocks the LUT and input-credit refunds.

Every April

Renew the LUT

It expires with the financial year. Refile RFD-11 before your first export invoice, or your 0% billing loses its legal cover.

Returns

GSTR-1 and GSTR-3B

Report export turnover at 0%, monthly or under QRMP. Registered exporters can claim refunds of unutilised input tax credit on business expenses.

Pillar 3 · Income tax

Foreign income is fully taxable in India.

As professional income, at slab rates. The good news is Section 44ADA.

50%deemed profit

Under 44ADA, half your gross receipts is simply deemed taxable profit — no books, no audit, no expense-tracking. Available on professional receipts up to ₹75 lakh when ≥95% arrives digitally.

15 Maradvance tax

Foreign clients deduct no Indian TDS. Under 44ADA, pay 100% by 15 March; under regular provisions, quarterly. Shortfalls attract 1% a month.

31 JulITR due

ITR-4 for presumptive filing; ITR-3 if you keep books and claim actual expenses. Forex converts at the SBI TT buying rate on the date of receipt.

If a client's country withheld tax, file Form 67 before your ITR and claim foreign tax credit under the DTAA. No double taxation — but only if you file it.
Pillar 4 · Registrations

What's mandatory vs merely smart.

Essential

Dedicated current account

Separate freelance money from personal funds — clean trails for ITR, GST refunds and any scrutiny.

Recommended

MSME (Udyam)

Free. Opens collateral-free credit, delayed-payment protection and scheme access.

Optional

IEC

Not needed for pure service exports. Your PAN doubles as the IEC. Take it only for goods or DGFT incentives.

Situational

STPI / SOFTEX

Only when software exports are STPI/SEZ-routed or your bank specifically asks.

Reality check on incentives: SEIS ended after FY 2019-20 and RoDTEP covers goods only. For a service freelancer today, the real benefit stack is 0% GST + ITC refunds + EEFC flexibility — not scrip schemes.
Eagle Eye

The circular, then what it actually says.

The standing translations live here. The dated diary — warnings as they land, contributed by the CAs, with tags and a calendar — is Eagle Eye. Official text is linked. Not legal advice — your CA still signs.

Eagle Eyea CA · FEMA 23(R)/2026-RB

From 1 October 2026, service exports are formally declared.

Until now a lot of freelancers treated a Wise credit and a FIRC as “done.” The new regulations say every export of services needs an Export Declaration Form. Software, design, writing, teaching on Zoom — if the client is abroad, it is an export. The switch flips on 1 October, not “sometime later.”

Notification FEMA 23(R)/2026-RB · 13 Jan 2026 ↗

Eagle Eyea CA · A.P. (DIR) Circular 20

One EDF a month. Due 30 days after month-end.

You do not file a form per invoice. You bundle every foreign invoice from that calendar month into one EDF. Invoice in October? File by 30 November. Your AD bank then has five working days to put it into EDPMS. Miss the window often enough and credits get slower, not because RBI froze you overnight, but because the bank cannot match money to a declaration that isn’t there.

A.P. (DIR Series) Circular No. 20 · 16 Jan 2026 ↗ · EDF form (PDF) ↗

Eagle Eyea CA · Circular 12 / 2025-26

Small invoices can close on your word.

If a single EDPMS entry is ₹10 lakh or less, your bank may close it on a declaration that the money has arrived — you do not need a novel of paperwork. Several such entries can go in one quarterly declaration. That is the relief. It is not a free pass to skip the EDF itself.

A.P. (DIR Series) Circular No. 12 · 1 Oct 2025 ↗

Eagle Eyea CA · realisation clock

Bring the money home in 15 months.

The EDF says you exported. The realisation rule says the rupees (or the EEFC dollars) must actually arrive, generally within fifteen months of the invoice — eighteen if you billed in INR. Sit on an unpaid invoice past that and future exports can be restricted to full advance or a letter of credit. Collect. Match. Close.

Same Circular No. 20, realisation provisions ↗

The diary keeps going as circulars land. Open Eagle Eye →

Before you send the next invoice

Five golden rules.

  1. Bank channels only — and always with the purpose code that matches your work.
  2. Collect the FIRC / e-FIRA for every payment; it powers your GST zero-rating.
  3. Keep the LUT alive — refile RFD-11 each April, before invoice #1 of the year.
  4. Pay your own tax: 100% advance tax by 15 March under 44ADA. No client will do it for you.
  5. Reconcile invoice → bank credit → e-FIRA monthly, and keep the file for 6+ years.
Educational overview, not tax or legal advice — thresholds shift with every Budget and GST Council meeting. Confirm specifics with your CA.
Or don't memorise any of it

TaxEagle runs this calendar for you. A CA signs off.

Tell it who paid you. It raises the invoice, matches the money, files what's due. First month free for founding members.