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ComplianceBeginner5 min readUpdated May 2026

GST Registration for an Indian Subsidiary: Step-by-Step

GST registration is mandatory for any Indian entity that makes taxable supplies, including IT service exports (which are zero-rated but still require a GSTIN). The registration process, the distinction between CGST/SGST/IGST, and the filing obligations that follow are foundational knowledge for every GCC finance team.

Key takeaways

  • IT service exports to a foreign parent are zero-rated under GST - no GST is charged, but a GSTIN is required to claim input tax credit on Indian vendor invoices.
  • GST registration is state-specific - a GCC with offices in multiple states needs a separate GSTIN for each state.
  • GSTR-3B (monthly summary return) is due by the 20th of the following month and must be filed even if the period's tax liability is nil.
  • Export refunds (IGST paid on exported services or accumulated ITC on zero-rated exports) can be claimed via Form RFD-01 and are typically processed within 60 days.
  • The GST officer may conduct a field verification at the registered office address before granting registration - ensure the office is accessible and signage is visible.

By irpr.network GCC Advisory Team - Published February 2025

CGST, SGST, IGST, and UTGST: Understanding the Structure

India's GST is a dual structure. Central GST (CGST) and State GST (SGST) apply to supplies made within the same state - the total rate is split equally between the centre and the state. Integrated GST (IGST) applies to inter-state supplies and imports, and is administered entirely by the central government. UTGST (Union Territory GST) applies to Union Territories without a legislature.

For a GCC exporting services to a foreign parent, the supply is zero-rated under Section 16 of the IGST Act. Zero-rated does not mean no GSTIN is required - it means the tax rate is zero, and the entity may claim a refund of input tax credit on all inputs used to provide those zero-rated services.

If the GCC also provides services to Indian entities (e.g., shared IT services to an Indian affiliate), those supplies are taxable at the applicable GST rate (typically 18% for IT services). This creates two streams: zero-rated exports and domestic taxable supplies, each tracked separately in the GST returns.

The Registration Application Process

GST registration is applied for on the GST portal (gst.gov.in). The application requires: PAN of the company, certificate of incorporation, authorized signatory's Aadhaar (for Indian residents) or passport (for foreign nationals), proof of registered office address (utility bill + NOC for virtual offices), nature of business (select 'SEZ unit' if applicable), HSN/SAC codes for the primary services.

The Application Reference Number (ARN) is generated immediately. Within 3 working days, the GST officer processes the application. If documents are in order, the GSTIN is issued via email. If the officer requires physical verification (more common for new entities without established business presence), a site visit is scheduled and the GSTIN is issued within 7 working days of the visit.

For GCCs that are SEZ units, there is a separate GST registration pathway for SEZ units versus their domestic tariff area (DTA) counterparts. An SEZ unit's supplies to DTA are treated as imports into DTA and attract applicable customs duties and IGST, whereas the SEZ unit's exports are zero-rated.

Apply for GST registration before any vendor invoices

Input tax credit (ITC) on vendor invoices issued before GST registration cannot be claimed retrospectively. Apply for GST registration at the same time as or immediately after incorporation, even if the first client invoice is months away. The monthly cost of maintaining a nil GSTR-3B is negligible.

Monthly GST Returns: What a GCC Files

GSTR-1: Outward supply statement, due by the 11th of the following month. For a GCC exporting services, all export invoices are reported here under the 'Exports' section with a unique Invoice Reference Number (IRN) or without LUT/bond if IGST is being paid and refunded.

GSTR-3B: Monthly summary return with net tax liability, due by the 20th of the following month. Even for a pure export GCC with zero GST liability, GSTR-3B must be filed. The return shows the ITC claimed for the month and carries it forward to the refund application.

LUT (Letter of Undertaking): GCCs that export services without paying IGST (i.e., claiming the export as zero-rated without upfront payment) must file an annual LUT on the GST portal. Filing the LUT at the start of each financial year (before the first export invoice in April) ensures exports are zero-rated without requiring payment and refund.

Glossary terms referenced in this guide

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