Recommended Free Tools
A foreign shipping company cannot claim an Indian GST refund simply because it is foreign or has paid GST on India-related costs. It must identify a refund ground that applies to its own transactions, meet the relevant registration and filing requirements, and provide evidence for the particular claim. For a qualifying zero-rated supply, the two possible routes are generally to supply under a bond or Letter of Undertaking (LUT) without payment of IGST and claim eligible unutilized input tax credit, or to pay IGST and seek a refund of that tax. Which route applies depends on the company’s contracts, services, recipient, route and tax treatment.
First establish what the company is claiming
Start with the legal entity that paid or bore the tax and the transaction behind the proposed claim. A carrier’s own Indian supplies, purchases and input services are not the same as freight supplied by a foreign carrier to an overseas exporter or an Indian importer. Nor does a tax charge on a business expense, by itself, establish a right to a refund.
For each transaction, identify:
- Which entity contracted, supplied or received the service, and which entity paid the tax.
- The service and route, including where the recipient is located and the relevant place-of-supply treatment.
- Whether the company is registered in India and whether it charged or paid IGST, or is claiming eligible input tax credit.
- The specific legal refund ground and the records that support it.
The GST Council has discussed international freight and foreign shipping lines in meeting agenda materials, but those materials are policy context, not a binding decision on a particular company’s refund entitlement. See the 52nd meeting agenda and the 49th meeting agenda note.
Does the company need Indian GST registration?
Registration depends on the company’s activities and circumstances; foreign status alone does not establish that every shipping line must register as a non-resident taxable person. Where that category applies, section 27 of the CGST Act provides that registration lasts for the period stated in the application or 90 days, whichever is earlier. An officer may extend it, for sufficient cause, by up to a further 90 days. The applicant must deposit an advance amount equal to its estimated tax liability for the registration period when it applies, and it may make taxable supplies only after registration is issued. Check the operative section 27 text and requirements for the relevant period on the CBIC Tax Information Portal.
What’s actually slowing this PC down?
Pick the symptom - the matching free tool is one click away.
#1 Best Overall
Which refund route could apply?
The two routes below concern qualifying zero-rated supplies: exports and supplies to a Special Economic Zone (SEZ) unit or developer. They are not general methods for recovering any GST charged on a shipping company’s costs. The IGST Act sets out the routes subject to applicable statutory conditions and procedures; check the current section 16 text for the transaction period through the CBIC Tax Information Portal. The CBIC also publishes an IGST Act text.
| Route | What the company does | What it seeks to recover |
|---|---|---|
| Supply under bond or LUT without payment of IGST | Uses a bond or Letter of Undertaking for an eligible zero-rated supply, subject to the applicable rules. | Refund of eligible unutilized input tax credit, not an automatic refund of every input tax charge. |
| Pay IGST on the qualifying supply | Pays IGST on an eligible zero-rated supply and follows the refund procedure that applies. | Refund of the IGST paid, subject to the applicable conditions. |
A company should not choose between these routes until it has established that its own supply qualifies as zero-rated and confirmed the conditions and procedures in force for that supply.
How to file a general refund claim
The general refund process uses electronic FORM GST RFD-01 through the common portal or a notified facilitation centre. The documents depend on the refund ground; the application is not supported by one universal document list. The CBIC Refund Rules and Rule 89 on the CBIC Tax Information Portal set out the application and evidence requirements.
For a claim relating to export of services, Rule 89 identifies a statement of invoices and relevant bank realization certificates (BRCs) or foreign inward remittance certificates (FIRCs). Other grounds call for evidence appropriate to those grounds. When the claim is for refund of unutilized input tax credit, the rules provide for a corresponding debit from the electronic credit ledger; see the CBIC Payment Rules.
Prepare the supporting records
- Contracts, invoices and records identifying the claimant, supplier, recipient and service.
- Route and recipient-location details relevant to the supply and place-of-supply analysis.
- Proof of tax payment or records reconciling the tax invoices, returns and credit ledger, as relevant to the refund ground.
- For an export-of-services claim, the invoice statement and relevant BRC or FIRC evidence specified by the rules.
- Any other evidence required for the particular ground under the applicable rules.
Why a shipping bill is not a carrier’s general refund application
Rule 96 addresses refund of IGST paid on goods exported from India. Under its prescribed conditions, the shipping bill is treated as the refund application after the required export manifest or report is filed and a valid GSTR-3B return has been furnished; the rule also addresses mismatches between shipping-bill and return data. The mechanism concerns the exporter and IGST paid on exported goods. It does not, by itself, make a foreign carrier the exporter or refund GST the carrier paid on its own inputs. See Rule 96 on the CBIC Tax Information Portal.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Check the claim before filing
- Map the transaction. Identify the contracting and paying entities, recipient, service, route, invoices and tax treatment.
- Confirm registration and returns. Determine whether the company needs Indian registration, whether it is registered for the relevant period, and whether the required returns and records are in order.
- Select the legal ground. Establish whether the claim is for tax paid on a qualifying zero-rated supply, eligible unutilized input tax credit or another applicable refund ground. Do not treat an input cost as refundable without an established ground.
- Match evidence to the ground. Reconcile invoices, tax payments, returns and credit-ledger entries; gather export or remittance evidence where the rules require it.
- File through the applicable process. Use FORM GST RFD-01 for a general refund claim, unless a distinct statutory mechanism applies, and retain the filing and supporting records.
The applicable notifications, rules and portal requirements can change. The company’s contracts, recipient, route, registration and tax-payment mechanism determine the result, so confirm the law for the transaction period and obtain India GST advice on the specific fact pattern before filing.
Quick Recap
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
