Indian clinical research organisations (CROs) should keep an engagement-level file that connects the overseas contract and work performed to the export invoice, qualifying payment, GST return, refund calculation and input tax credit (ITC) claimed. For exports made without payment of IGST, retain the filed Letter of Undertaking (LUT) or bond as well. Some records are specifically called for under GST rules; others, such as deliverables and client approvals, are prudent evidence that helps substantiate the transaction.
Documents to keep for each CRO export engagement
Maintain one traceable file for each engagement, with records linked by contract, work order, invoice and payment references. The checklist below distinguishes records identified in the rules from supporting evidence that helps explain the service and reconcile the claim; it is not a claim that every item must be attached to every refund application.
| Record | What to retain | Why it matters |
|---|---|---|
| Contract and service-delivery evidence | Signed master services agreement, statements of work, amendments, purchase or work orders, milestone schedules, deliverables, client approvals or acceptance, and material correspondence. | Prudent evidence of the contracting parties, agreed scope, services actually performed and intended recipient. These materials help establish the facts behind the export treatment. |
| Export tax invoices | Sequential invoice register and invoice copies with recipient name and address, delivery address and destination country particulars, plus the applicable export endorsement. | Invoice rules specify export particulars and endorsements. The invoice also anchors the return, receipt and refund records. |
| LUT or bond for the no-IGST route | Filed FORM GST RFD-11 LUT or bond and filing acknowledgement. | Rule 96A requires the LUT or bond before making an export supply under this route. |
| Payment and remittance evidence | Bank Realisation Certificate (BRC) or Foreign Inward Remittance Certificate (FIRC) details, bank advice and remittance records, mapped to invoice number, date, amount, currency and receipt date. | Refund rules require invoice and relevant BRC/FIRC details for export-of-services refund statements. Supporting bank records explain grouped or split receipts, charges, deductions, advances and currency conversion. |
| Returns and refund records | GSTR-1 filing details and acknowledgements, RFD-01 application and schedules, invoice-wise export statement, refund calculation, notices and responses, and any sanction or deficiency orders. | These records show what was reported and claimed, and preserve the claim history. |
| Books and ITC support | Sales, tax, input-tax and ITC accounts; inward tax invoices; credit and debit notes; and a reconciliation of eligible ITC to the refund claimed. | CBIC account-record rules address service inputs used and services supplied, with audit-trail links to source documents and financial accounts. |
Use the correct invoice endorsement
For an export made on payment of IGST, the prescribed endorsement is “SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGST”. For the no-payment route, use “SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST”. The invoice rules generally set a 30-day time limit from the supply of a service, subject to specified exceptions. Confirm the applicable timing and invoice particulars for the transaction.
Map payments to invoices
A payment record is most useful when the mapping is clear. If a client remits one amount against several invoices, or pays an invoice in parts, retain a schedule showing the allocation and supporting bank records. Note any bank charges, deductions, advance receipts and exchange conversion so the amount and receipt date used in the GST records can be explained.
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How the export file supports the refund claim
Build a reconciliation that can be followed from the engagement through the books and GST filings. A practical sequence is:
- Establish the engagement: identify the parties and agreed services from the executed contract, work order and amendments.
- Show the work performed: retain relevant deliverables, milestone records, client approvals and correspondence that support the invoiced service.
- Connect service to invoice: link each invoice to the relevant scope or milestone and include the required export particulars and endorsement.
- Connect invoice to receipt: map BRC/FIRC and bank evidence to the invoice, explaining allocations or differences where needed.
- Connect the transaction to filings: retain GSTR-1 reporting details, the refund application and schedules, and workpapers that reconcile the claimed amount to invoices, receipts, returns and ledgers.
- Support the ITC claimed: trace eligible input tax to inward invoices and accounting records, and reconcile it to the refund calculation.
GST Portal guidance says export invoices may be reported in GSTR-1 before shipping-bill details are available, with those details added by amendment in a later period. Preserve the original filing and any later amendment so the reported information can be followed over time.
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Choose and document the applicable zero-rating route
The GST Portal describes two broad routes for zero-rated supplies. The route used affects whether IGST was paid upfront and what the refund calculation concerns. Eligibility and current restrictions should be checked for the particular claim.
| Route | What is paid upfront | Refund focus | Core records to preserve |
|---|---|---|---|
| Export without payment of IGST | No IGST is paid on the export supply under the LUT or bond route. | Refund of eligible unutilized ITC, subject to applicable rules. | Filed LUT or bond and acknowledgement; correctly endorsed export invoices; relevant return and refund records; invoice-to-receipt evidence; ITC ledger and calculation support. |
| Export on payment of IGST | IGST is paid on the export supply. | Refund of tax paid, subject to applicable rules and restrictions. | Correctly endorsed export invoices, records supporting payment and reporting, refund application and supporting schedules. |
For the no-IGST route, Rule 96A requires FORM GST RFD-11 to be furnished before the export supply. It also provides that if payment for exported services is not received in convertible foreign exchange, or in Indian rupees where the Reserve Bank of India permits, within one year from the invoice date or an allowed further period, tax and interest consequences may follow. Track invoice dates against receipts and any permitted extension.
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Check whether the CRO supply qualifies as an export of services
Under the export-of-services conditions described in CBIC’s sectoral FAQs, the supplier must be located in India, the recipient outside India, the place of supply outside India, and consideration received in convertible foreign exchange or in Indian rupees where RBI permits. The supplier and recipient must not merely be establishments of the same person.
An overseas customer or a contract labelled “clinical research” does not by itself establish export treatment. Review the operative contract and actual workflow: who supplies each service, who receives it, whether the CRO acts as principal or arranges a supply between other parties, and where the relevant recipient and place of supply are located. Intermediary classification is fact-sensitive; a conclusion for a particular engagement requires review of its agreements and service model.
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Calculate export turnover using the relevant period’s facts
For a refund of unutilized ITC, the refund rules define export turnover of services by reference to payments received during the relevant period, completed services for which advance payment was received earlier, and advances received for services not completed during that period. Accordingly, an export invoice does not by itself establish that its full value belongs in a particular refund period.
Reconcile the turnover and refund calculation to the applicable receipts, service-completion records, returns and ledgers. Keep the calculation workpaper and its underlying invoice, payment and service evidence together so the treatment of advances and timing differences is clear.
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