Which Purpose Codes Qualify as Export of Services for GST?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
- Published:
- Last modified:
Short answer
No RBI purpose code makes a supply an export of services for GST. Qualification depends on the five conditions in section 2(6) of the IGST Act, such as a recipient outside India and payment in convertible foreign exchange. Service codes like P0802, P1006 and P1099 only record the nature of the receipt for RBI.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Service exporters in India comparing FEMA purpose codes with GST export status | IGST Act, 2017 sections 2(6) and 16, and the RBI FETERS purpose code list | Not applicable | IGST may be payable if a supply fails the section 2(6) conditions | 9 Oct 2026 |
Does a purpose code decide whether a supply is an export of services for GST?
No. A purpose code is an RBI reporting label, while export of services is a GST status set by section 2(6) of the IGST Act. A supply can carry a service purpose code and still fail a GST condition, such as place of supply.
- Supplier: The supplier of the service must be located in India (section 2(6)(i)).
- Recipient: The recipient must be located outside India.
- Place of supply: The place of supply must be outside India.
- Payment: Payment must be received in convertible foreign exchange, or in Indian rupees where RBI permits.
- Separate persons: The supplier and recipient must not be merely establishments of a distinct person.
For the definitions side by side, see export of services under FEMA vs GST. For the tax, see GST on export of services.
Which service purpose codes are commonly used for exports that may qualify under GST?
Codes in Groups 08 and 10 cover most freelance and IT services. The table shows the verbatim RBI description, and each service still needs the GST test.
| Code | RBI description | GST step | Best for |
|---|---|---|---|
| P0802 | Software consultancy/implementation (other than those covered in SOFTEX form) | Test all five section 2(6) conditions | Software consultants |
| P0807 | Off site software exports | Test all five section 2(6) conditions | Developers delivering software |
| P1006 | Business and management consultancy and public relations services | Check place of supply for PR tied to events in India | Consultants and PR professionals |
| P1007 | Advertising, trade fair service | Check place of supply for event based work | Marketing freelancers |
| P1099 | Other services not included elsewhere | Test all five section 2(6) conditions | Service exporters with no closer code |
How do you check whether a service export qualifies for GST zero rating?
Test the supply against all five section 2(6) conditions, then confirm the place of supply under the IGST Act. Use the purpose code only as the RBI record of the receipt. Keep the invoice, contract and bank advice together.
- Confirm your location and the client's location from the contract and invoice.
- Work out the place of supply under the IGST Act for the service.
- Confirm payment is in convertible foreign exchange, or in rupees where RBI permits.
- Check that you and the client are not merely establishments of one person.
- File an LUT if you are registered and want to export without paying IGST.
- Record the purpose code your AD bank applied and keep the advice.
How does a Letter of Undertaking relate to service purpose codes?
An LUT lets a registered person make zero rated supplies without paying IGST under section 16(3). It is filed as FORM GST RFD-11 and has no link to the purpose code. See CGST Rule 96A.
How does FIRA relate to GST proof of export of services?
A FIRA records the foreign currency receipt and the purpose. The inward remittance advice or certificate your AD bank issues normally records the purpose of the payment. Keep it with the invoice and contract. Check with your AD bank on the exact format it issues.
- CBIC Circular 161/17/2021-GST deals with condition (v) of section 2(6). Read it for what counts as payment in convertible foreign exchange.
- See what is FIRA.
Which purpose codes and GST conditions are most often confused?
The two systems test different things. The table compares them.
| Question | FEMA purpose code | GST export of services | Best for |
|---|---|---|---|
| What it records | Nature of the receipt for RBI | Whether the supply is zero rated | Exporters reconciling both |
| Legal source | RBI FETERS list and FEMA regulations | IGST Act section 2(6) and section 16 | Exporters preparing records |
| Who applies it | AD bank on the inward remittance | The supplier on the invoice and returns | Registered service exporters |
| Effect of a wrong entry | Bank query or correction | IGST may become payable | Exporters answering notices |
What happens if a supply fails the section 2(6) conditions for GST?
If a supply fails a condition, it is not an export of services and IGST may be payable on it. A correct purpose code does not cure this. Check the facts with a tax professional.
- Tax payable: The supply may attract IGST at the applicable rate.
- LUT: Supplying under an LUT without meeting the conditions can lead to recovery and notice.
- Refund: A refund claim can be rejected if the supply is not zero rated.
Review the contract, invoice and payment trail with a tax professional. See GST refund on export of services.
Which rules set the GST test and the purpose code for service exports?
The IGST Act sets the GST test and the RBI FETERS list sets the codes. The two are separate.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| IGST Act, 2017 | Section 2(6) | Act in force | Five conditions for export of services | Testing a supply |
| IGST Act, 2017 | Section 16 | Act in force | Export of services is zero rated; LUT route in section 16(3) | Planning tax |
| CGST Rules, 2017 | Rule 96A | Rules in force | Export under bond or LUT | Registered exporters |
| A.P. (DIR Series) Circular No. 84 | Annex I | 29 February 2012 | Purpose codes for receipts | Choosing a code |
| FEMA 23(R)/2026-RB | Regulation 5(1)(a) | In force 1 October 2026 | Nine months to realise export value, twelve if invoiced or settled in rupees | Payment timelines |
What mistakes do exporters make when linking purpose codes to GST export status?
- Code equals status: Assuming a service code proves GST export status.
- Place of supply: Skipping the place of supply test for event or location based services.
- No LUT: Exporting without an LUT and without paying IGST.
- Rupee payment: Receiving rupee payment without checking RBI permission.
- Related parties: Ignoring the condition on establishments of a distinct person.
- Weak records: Keeping the invoice and bank advice in separate places.
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- RBI: Guidelines for Submission of Data, FETERS, purpose code list for receipts (A.P. (DIR Series) Circular No. 84, 29 February 2012), Annex I, receipt purposes (checked 9 Oct 2026)
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB, amended up to 22 September 2026 (checked 9 Oct 2026)
- IGST Act, 2017, Section 2: Definitions (CBIC tax information portal), Section 2(5) export of goods, section 2(6) export of services (checked 9 Oct 2026)
- IGST Act, 2017, Section 16: Zero rated supply (CBIC tax information portal), Section 16(1) to (3) (checked 9 Oct 2026)
- GST Portal user manual: Furnishing of Letter of Undertaking (FORM GST RFD-11) (checked 9 Oct 2026)
- CGST Rules, 2017: Rule 96A (Export of goods or services under bond or Letter of Undertaking), Rule 96A (checked 9 Oct 2026)
- CBIC Circular No. 161/17/2021-GST: Clarification relating to export of services, condition (v) of section 2(6) of the IGST Act, 20 September 2021 (checked 9 Oct 2026)
Frequently asked questions
Is there a list of purpose codes approved for GST export of services?
No official list ties purpose codes to GST export status. The IGST Act section 2(6) sets the conditions, and the RBI FETERS list is a separate reporting list. A supply is tested against the Act, not the code.
Does P0802 prove that a software supply is an export of services?
No. P0802 only describes the receipt as software consultancy or implementation outside SOFTEX. The supply still has to meet all five conditions in section 2(6) of the IGST Act, including place of supply outside India.
Can a service be an export under GST if payment arrives in rupees?
Section 2(6) allows payment in Indian rupees where RBI permits it. Check the RBI permission that applies to your payment route and ask your AD bank. Keep the bank advice with the invoice.
Does using P1099 affect zero rating of a service supply?
No. P1099 is the residual RBI code for other services not included elsewhere. Zero rating depends on the section 2(6) conditions and section 16 of the IGST Act, not on which RBI code the bank applied.
Do I need an LUT to claim export of services status?
An LUT lets a registered person export without paying IGST under section 16(3). Without it, a registered exporter may pay IGST and claim a refund instead. See the linked guides on LUT and refunds.
Where can the FIRA help with GST export proof?
A FIRA records the foreign currency receipt and its purpose. It supports proof of payment in convertible foreign exchange, one of the five conditions. Keep it with the invoice and contract for GST records.