In view of the issues faced by exporters, the Government of India has notified supplies which would qualify as deemed exports and the concessional duty rates for the last leg of supply made to exporters when such goods are being exported as such.

The Government has notified following supplies as "deemed export":

  • Supply of goods supplied against an Advance Authorisation
  • Supply of capital goods supplied against an Export Promotion Capital Goods (EPCG) Authorisation
  • Supply of goods to an Export Oriented Unit (EOU)
  • Supply of gold by Banks/Public Sector Undertakings (as specified under Notification No. 50/2017 – Cus dated 30 June 2017) against an Advance Authorisation.

The recipient shall be entitled to seek a refund of tax paid against deemed export. Alternatively, the supplier can also seek refund of tax on submission of disclaimer certificate from the recipient about non-availment of refund/input tax credit by the recipient.

The Government has notified that the penultimate supply of goods for export as such would be taxed at 0.1% of GST (cumulative rate). Such goods should be directly delivered to customs port or registered warehouse and exported within a period of 90 days.


The new changes ensure continuity of the benefits enjoyed by exporters under the erstwhile tax regime. However, it remains to be seen whether the suppliers will walk the extra mile to accommodate exporters by taking the burden of filing refund claims. Online refund facility is yet to be activated and therefore, suppliers may be reluctant to block their working capital by availing the concessional rate benefit when supplying to merchant exporters.

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