Export Services- Invoicing Query

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This query is : Resolved

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A freelancer software consultant earning foreign exchange for export services is seeking advice on issuing export invoices to comply with GST LUT conditions. Despite receiving payments from Upwork and directly from US clients, they haven't been asked for invoices. The consultant needs clarification on whether to raise an export invoice, if recipient acceptance is required, or if keeping records suffices, especially after obtaining BRC/FIRC.

Rahul

Rahul (Querist)
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14 May 2020 A freelancer software consultant likely to have 25-30lakhs turnover p.a for the current year from export software services has obtained recently the following registrations,
1. GST Regn
2. LUT fiing
3. IEC Regn

He provides his services via Upwork website-
1. Where he provides services to American clients but receives forex from Upwork.
2. Also, he sometimes directly provides services to American clients and receives forex in his payment gateway directly from American clients(ex:paypal)

In both the above cases, neither Upwork nor American client asks for his Export bill because they maintain a statement of hours worked and based on that they pay the Software consultant.

So, to satisfy LUT conditions in gst one has to
1. To receive forex (consideration) for his services
2. Obtain BRC/FIRC from the bank
and
3. Raise an Export Invoice for Services

In the said case, he receives forex and can request the banker for BRC/FIRC.

But how do we invoice the Upwork website or the American client ?

My doubts here are,
1. Should we raise an Export Invoice and mail them
2. Does our Invoice need acceptance from the recipient of Services
3. Or can we just raise the Invoice and keep it in our records and not submit to them.

Kindly guide me over these doubts. Also, kindly let me know if i have missed any points as far as export of services are concerned.