What Is the P1004 Purpose Code?

The P1004 purpose code covers money received from abroad for legal services. RBI lists P1004 in group 10, Other Business Services, and gives it the single description "Legal services". In plain terms, P1004 applies when a foreign client pays an Indian lawyer, law firm or legal support provider for legal work. RBI does not publish a longer definition, so the invoice and contract wording is what shows the nature of the work. AD banks report the chosen code under FETERS, as set out in A.P. (DIR Series) Circular No. 84 of February 29, 2012. Regulation 18(2) of the 2026 Export and Import Regulations keeps this FETERS reporting in place.

P1004 vs P1006: P1006 is "Business and management consultancy and public relations services" in the same group. Both codes cover professional advice. If the work is legal, such as contract drafting, legal opinions or compliance advice on law, P1004 is the closer match. If the advice is about strategy, operations or communications, P1006 is the closer match. See P1006.

Use the P1004 purpose code when a foreign client pays you for legal work. Typical cases are contract drafting and review, legal opinions, legal research, patent or trademark drafting support, and outsourced legal process work. The deciding question is what your invoice and contract describe. Group 10 of the RBI purpose code list has separate codes for related professional services, so check the alternatives below before you choose P1004.

• Use P1005 instead: Use P1005 (Accounting, auditing, book keeping services) when the client pays for accounting, audit or bookkeeping rather than legal work.
• Use P1015 instead: Use P1015 (Tax consulting services) when the advice is about tax matters.
• Use P1006 instead: Use P1006 (Business and management consultancy and public relations services) when the work is business or management advice rather than legal advice.

The P1004 purpose code is used by Indian residents who sell legal services to clients outside India, such as advocates, law firms, in-house legal consultants working for overseas clients, and legal process outsourcing firms. The Indian recipient of the payment declares P1004 to the AD bank or payment provider that credits the foreign currency.

• For example, a Delhi law firm drafts a shareholders' agreement for a Singapore company and receives its fee under P1004.
• For example, a freelance legal researcher in Pune prepares case law summaries for a US law practice and declares P1004.
• For example, a Bengaluru lawyer reviews vendor contracts for a UK startup on a monthly retainer and is paid under P1004.
• For example, a legal process outsourcing firm in Gurugram handles contract abstraction for an overseas corporate client and receives payment under P1004.

• The client pays for bookkeeping, accounting or audit work. Use P1005 (Accounting, auditing, book keeping services).
• The client pays for tax advice or tax return advisory. Use P1015 (Tax consulting services).
• The client pays for business strategy or public relations advice. Use P1006 (Business and management consultancy and public relations services).
• The work is a one-time sale of goods or a software service, not legal work. Use The goods or software code that matches the invoice, such as P0802 (Software consultancy/implementation (other than those covered in SOFTEX form)).

For the P1004 purpose code, the core documents are the invoice, the contract or engagement letter, and an Export Declaration Form (EDF). Under Regulation 3(2) of the 2026 Export and Import Regulations, in force from October 01, 2026, an exporter of services must furnish an EDF with the full export value. For services other than software, the EDF may be submitted on or before the date of receipt of payment. This changes paragraph B.7 of the Master Direction, superseded by A.P. (DIR Series) Circular No. 20, which let such services be exported without a declaration.

• Invoice: Raise an invoice naming the foreign client and describing the legal service, the matter or period covered, the amount and the currency.
• Contract: Keep the engagement letter, retainer agreement or email confirmation that shows the scope of the legal work.
• EDF: Submit the Export Declaration Form to an Authorised Dealer in the DTA, or to the SEZ Development Commissioner in an SEZ. One EDF can cover all services exported to one or more recipients in a month. SOFTEX did not apply to this type of service.
• Work evidence: Keep a record of the work delivered, such as the opinion or agreement sent to the client, in case the bank or a tax officer asks what was supplied. Keep client confidentiality in mind when sharing it, and share only what is needed.
• Bank requests: Your AD bank may ask for KYC details or the remitter's details. Under Regulation 4(2), invoices up to ₹10 lakh can be closed in EDPMS on your declaration that the payment has been realised.

1. Check the invoice and contract to confirm the payment is for legal services for a foreign client.
2. Open the inward payment in your bank or payment provider's portal, app or branch form when the foreign currency arrives or when you are asked for the purpose.
3. Select P1004 from the purpose code list, or write the code and its description if the form asks for text.
4. Attach or keep ready the invoice, contract and Export Declaration Form, and add the invoice number in any remarks field so the payment can be matched.
5. Confirm the code shown on the credit advice or inward remittance certificate is P1004, and ask your bank or payment provider to correct it if it is wrong.

• FIRA/FIRC: The inward remittance advice or certificate your bank or payment provider issues normally records the purpose of the payment. Keep it with the matching invoice. Check with your AD bank on the exact format it issues.
• GST status: Legal work for a foreign client is an export of services only if all five conditions in section 2(6) of the IGST Act are met. These include the place of supply being outside India, so advice on a matter that depends on property or events in India needs a separate place of supply check with a tax professional. A zero rated supply under section 16(1)(a) of the IGST Act can be made under a Letter of Undertaking filed as FORM GST RFD-11.
• Zero rating: Export of services is a zero rated supply under section 16(1)(a) of the IGST Act, and input tax credit may be availed for it under section 16(2).
• LUT: Section 16(3) allows a registered person to make zero rated supplies without payment of integrated tax under bond or Letter of Undertaking. The LUT is filed as FORM GST RFD-11 on the GST portal.
• Income tax: The purpose code does not change how the income is taxed. Receipts for this service are part of your income and are reported in your return. The Income-tax Act, 2025 replaced the 1961 Act from 01.04.2026. Take advice from a tax professional on the correct head and return form.
• Realisation: Under Regulation 5(1)(a) of the 2026 Regulations, the export value of services must be realised and repatriated within nine months from the date of invoice, or twelve months where the export is invoiced or settled in Indian rupees. The September 22, 2026 amendment cut these from fifteen and eighteen months. Your AD bank may extend the period on request.

• Assumed meaning: Treating P1004 as a code for any professional service. RBI describes P1004 as Legal services only.
• Accounting work: Declaring P1004 for bookkeeping or audit support, which RBI lists under P1005 (Accounting, auditing, book keeping services).
• Tax advice: Using P1004 for tax advisory fees, which RBI lists under P1015 (Tax consulting services).
• Catch-all code: Using P1099 (Other services not included elsewhere) when P1004 describes the legal service.
• Personal codes: Selecting a transfer code such as P1302 (Personal gifts and donations) for legal fees, which misstates the nature of the receipt.
• No EDF: Assuming legal work needs no declaration. From October 01, 2026, Regulation 3(2) requires an EDF for services, filed on or before the date of receipt of payment for services other than software.

The code, its official description and every rule on this page are linked to RBI and other official sources, checked on the dates below.

1. RBI: Guidelines for Submission of Data, Foreign Exchange Transactions Electronic Reporting System (FETERS), purpose code list for receipts, Annex purpose codes, receipts, Group 10 Other Business Services: P1002, P1004, P1005, P1006, P1007, P1015, P1099; Group 13 P1302 (checked 9 Oct 2026)
2. RBI A.P. (DIR Series) Circular No. 84 dated February 29, 2012: Compilation of R-Returns, Reporting under FETERS, Paragraph 3: AD banks to report all foreign exchange transactions as per the revised purpose code list from April 2012 (checked 9 Oct 2026)
3. RBI Notification No. FEMA 23(R)/2026-RB: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to September 22, 2026), Regulation 1(2) (in force from October 01, 2026); 2(1)(f) (specified authority for services other than software); 3(2) and 3(2)(b) (EDF for services, on or before receipt of payment for non-software services); 4(2) (EDPMS closure up to ₹10 lakh); 5(1)(a) (nine months from invoice date, as amended on September 22, 2026); 18(2) (FETERS reporting) (checked 9 Oct 2026)
4. RBI A.P. (DIR Series) Circular No. 20 dated January 16, 2026: Export and Import of Goods and Services, Paragraphs 4 and 7 and Annex A: Master Direction on Export of Goods and Services and listed circulars, including the SOFTEX circulars, superseded from October 01, 2026 (checked 9 Oct 2026)
5. RBI: Export Declaration Form, Annex to the 2026 Regulations, Part 2B (details of services provided to multiple recipients) and Part 5 (certification by Custom, SEZ, Authorised Dealer or STPI) (checked 9 Oct 2026)
6. RBI Master Direction: Export of Goods and Services (updated as on July 17, 2026; superseded from October 01, 2026), Superseded from October 01, 2026; cited only to explain the earlier rule in paragraph B.7 (export of services without a specified form) (checked 9 Oct 2026)
7. IGST Act, 2017, Section 2: Definitions (CBIC tax information portal), Section 2(6): definition of export of services (checked 9 Oct 2026)
8. IGST Act, 2017, Section 16: Zero rated supply (CBIC tax information portal), Section 16(1)(a), 16(2) and 16(3): zero rated supply, input tax credit, supply under bond or Letter of Undertaking (checked 9 Oct 2026)
9. GST Portal user manual: Furnishing of Letter of Undertaking (FORM GST RFD-11), Filing path Services > User Services > Furnish Letter of Undertaking (LUT) (checked 9 Oct 2026)
10. Income Tax Department e-filing portal: Objective and scope of the New Act, Repeal of the 1961 Act on 01.04.2026 and the tax year concept (checked 9 Oct 2026)