Under the Goods and Services Tax (GST) law, supplies made to entities such as United Nations agencies, foreign embassies, consular posts, and other organizations of a similar nature are treated in the same manner as any other taxable supply of goods or services. This means that suppliers must charge GST on such transactions as per the applicable tax rates. However, these special entities hold a distinct status in international law and diplomatic practice, often enjoying exemptions from domestic taxation under bilateral or multilateral agreements. To ensure that GST does not become a financial burden on them, the law provides a mechanism allowing these organizations to claim a refund of the GST paid on their purchases, subject to the fulfilment of certain prescribed conditions.
The refund process for these entities is facilitated through the allocation of a Unique Identity Number (UIN), an exclusive identifier granted under the GST framework. The UIN acts similarly to a GST registration number but is designed specifically for refund purposes, not for tax collection or payment. This approach streamlines compliance and ensures that the transactions of such bodies are tracked in a structured manner without subjecting them to the full GST compliance obligations applicable to regular taxpayers.
Entities eligible for a UIN include foreign diplomatic missions, consular posts, United Nations organizations, specialized agencies, and other international bodies notified by the Government of India. The application for a UIN is made using Form GST REG-13, supported by documentary proof of eligibility, such as a letter from the Ministry of External Affairs or an equivalent authority. Once approved, the GST authorities issue the UIN, which must be quoted on all purchase invoices involving the entity.
Entities Eligible to Obtain UIN
The GST law specifies particular classes of persons and organizations that are eligible to obtain a Unique Identity Number. These primarily include:
Any specialized agency of the United Nations Organization or multilateral financial institutions and organizations that are notified under the United Nations (Privileges and Immunities) Act, 1947. These entities generally have privileges exempting them from regular taxation, but under GST, they must obtain a UIN to claim refunds.
Foreign diplomatic missions, such as consulates and embassies of other countries, also fall under the category of entities required to obtain a UIN for GST purposes.
Additionally, any other person or class of persons may be notified by the Commissioner for eligibility to obtain a UIN, though no such notifications have been made to date.
These entities apply for their Unique Identity Number by submitting Form GST REG-13 to the relevant GST authorities.
It is important to note that under the GST law, the term “registered person” excludes those holding a UIN. This means that entities with a UIN are not considered registered taxpayers under GST but have a special status allowing them to claim refunds on taxes paid.
Centralized UIN Facility
To reduce the compliance burden on these special entities, the GST law introduced a facility for centralized issuance of the Unique Identity Number (UIN). This reform, which became effective from December 29, 2017, was designed to address the challenges faced by foreign diplomatic missions, consular posts, United Nations agencies, and other notified organizations that operate in multiple states within India.
Before this amendment, UINs were issued on a state-by-state basis, meaning that an eligible entity with operations in several states had to apply for and maintain separate UINs for each location. This not only increased paperwork but also created multiple refund claims, each filed in the jurisdiction where the UIN was registered. Such duplication often led to delays, greater administrative workload, and the need for more coordination between state GST authorities and the entity in question.
Under the centralized UIN system, an eligible organization can obtain a single UIN that is valid across the entire territory of India. This UIN serves as the sole identifier for GST purposes, regardless of where the entity procures goods or services within the country. For example, a foreign embassy with offices in Delhi, Mumbai, and Chennai can now operate using one centralized UIN for all its transactions instead of maintaining separate UINs for each state. This simplifies not only the process of recording and tracking transactions but also consolidates refund claims into a single application, saving time and effort for both the entity and the tax authorities.
The Central Board of Indirect Taxes and Customs (CBIC) has clarified that obtaining a centralized UIN is optional. Entities may still opt for multiple UINs if they prefer to keep state-level separation for operational or internal accounting reasons. However, the majority of organizations have found the centralized system more convenient, particularly those with frequent interstate transactions or centralized procurement systems.
The refund process for a centralized UIN largely follows the same steps as before, but now the inward supply details from all states are compiled under one UIN and submitted through a consolidated GSTR-11 return. Correspondingly, the refund application in Form GST RFD-10 reflects all eligible purchases made under that UIN during the claim period, regardless of the state in which the purchase occurred.
From an administrative perspective, this reform reduces duplication of efforts, minimizes data entry errors, and allows quicker cross-verification of invoices between suppliers and UIN holders. It also aligns with the broader objective of GST—creating a unified national market with consistent tax compliance mechanisms. By introducing the centralized UIN facility, the GST framework demonstrates flexibility in accommodating the unique position of foreign and intergovernmental entities, while still maintaining the necessary safeguards to ensure legitimate claims and accurate reporting.
Refund Application Process for UIN Holders
Entities holding a UIN must follow a specified process to claim refunds of GST paid on their procurement of goods or services. The law outlines the following key steps for filing a refund application:
They must file a statement of inward supplies using Form GSTR-11 every quarter. This form captures the details of purchases made by the entity during the quarter.
Following this, the entity files a refund application in Form GST RFD-10, also every quarter. Importantly, this refund application can only be filed after the corresponding GSTR-11 statement has been submitted.
The applicant is required to prepare an undertaking that confirms compliance with the conditions prescribed under the GST law. This includes adherence to the letter of reciprocity issued by the Ministry of External Affairs, which sets out the conditions under which refunds are granted to foreign diplomatic and international entities.
The refund application, along with necessary documents, must be submitted manually to the designated Central Tax nodal officers appointed by the government.
The documents required to support the refund claim typically include a covering letter, copies of the filed GSTR-11 and GST RFD-10 forms, a detailed statement of invoices, certificates related to receipt of goods or services, the letter of reciprocity, prior permission letters for certain claims such as vehicle purchases, and a canceled cheque for the bank account mentioned in the refund form.
The tax authorities have clarified that Forms GSTR-11 and GST RFD-10 need to be filed separately only for those quarters where refund claims are made, avoiding unnecessary filings for quarters with no refund applications.
Importance of Mentioning UIN on Tax Invoices
Foreign diplomatic missions, United Nations organizations, and other entities holding a UIN often face challenges during the procurement of goods and services in India. One of the key issues reported is the reluctance or refusal of suppliers and vendors to record the UIN on the tax invoices issued to these entities.
Under the GST law, mentioning the UIN of the recipient on the tax invoice is a mandatory requirement. This information is essential to establish the eligibility of the entity to claim a refund of the GST paid. If vendors do not record the UIN on the invoices, it creates difficulties for the UIN holder when filing refund claims.
To address this issue, the government has issued clarifications emphasizing that recording the UIN on tax invoices is a necessary element. Suppliers who fail to include UIN details on the invoices can face enforcement actions under GST provisions.
Temporary Waivers on UIN Compliance
Recognizing the practical difficulties faced by entities and their suppliers, the government provided temporary relief by waiving the requirement to mention UIN on tax invoices for certain periods.
Initially, this waiver was granted for the period from April 2018 to March 2020. Subsequently, the waiver was extended for the period from April 2020 to March 2021.
These waivers were intended to ease compliance challenges while the ecosystem adjusted to the special requirements related to UIN. However, beyond these periods, the requirement to record UIN on tax invoices remains mandatory.
Legal Framework Governing UIN and Refunds
The Unique Identity Number and its related refund mechanism are governed by specific sections and rules under the Central Goods and Services Tax Act and Rules.
Section 25(9) of the CGST Act empowers the authorities to grant a UIN to specified entities and lays down the eligibility conditions.
Section 55 of the CGST Act prescribes the refund of tax paid, including the refund procedure applicable to UIN holders.
Rules under the CGST Rules, such as Rule 17(1A), Rule 82, and Rule 95, provide detailed guidelines on the issuance of UIN, the filing of inward supply statements, and refund applications, respectively.
Notifications issued by the government specify the conditions under which refunds are granted and outline procedural requirements. These notifications also describe the reciprocal treatment extended by India to foreign missions and international organizations based on principles of mutuality.
The Ministry of External Affairs plays a key role by issuing letters of reciprocity, which are prerequisites for processing refund claims for UIN holders.
Role of the Ministry of External Affairs and Reciprocity Letters
Refunds to foreign diplomatic missions and international organizations are processed based on the principle of reciprocity. This means that India grants tax exemptions or refunds to these entities only if their home countries offer similar privileges to Indian diplomatic missions and organizations.
The Ministry of External Affairs issues letters of reciprocity that certify the fulfillment of this condition. These letters are an essential document for the refund application filed by UIN holders.
Without a valid letter of reciprocity, refund claims cannot be sanctioned. Therefore, the cooperation between GST authorities and the Ministry of External Affairs is vital for the smooth processing of refunds.
Compliance Responsibilities of UIN Holders
Entities holding a Unique Identity Number under GST must adhere to specific compliance obligations to maintain their status and ensure smooth processing of refunds.
Filing of Form GSTR-11 is a key responsibility, which must be done quarterly. This form captures all inward supplies made to the UIN holder, providing a summary of purchases subject to GST during the quarter.
Subsequent to GSTR-11, the entity must file Form GST RFD-10 for claiming the refund of tax paid. The refund application depends on the inward supply statement already filed.
UIN holders must also ensure that all supporting documents accompanying the refund claim are accurate, complete, and submitted on time. These documents include detailed invoices, certificates related to the receipt of goods or services, and a letter of reciprocity from the Ministry of External Affairs.
Additionally, UIN holders are required to comply with prescribed undertakings confirming that all refund conditions are met, including adherence to GST rules and reciprocity agreements.
Failure to comply with these requirements can result in delayed refunds or rejection of claims.
Distinction Between UIN Holders and Regular GST Registrants
A Unique Identity Number holder differs significantly from a regular GST registrant. While a registered person under GST is subject to the full range of GST compliance, such as tax collection, input tax credit, and return filing, a UIN holder operates under a limited framework primarily focused on refund claims.
The definition of “registered person” under GST specifically excludes entities possessing a UIN. Therefore, these entities are not required to collect or pay GST on their supplies within India, but they must claim refunds on GST paid on their inward supplies.
This distinction is important because UIN holders do not have the same liabilities or obligations as regular taxpayers under GST, but they must still observe specific compliance procedures to avail refunds.
Challenges Faced by UIN Holders and Suppliers
Despite the provisions made for UIN holders, practical challenges continue to exist. Many suppliers and service providers remain unaware of the requirement to record UIN on invoices, leading to difficulties in refund processing for these entities.
In some cases, suppliers may be reluctant to deal with foreign missions or UN agencies due to perceived complexities or additional compliance requirements.
The lack of awareness among vendors about UIN has prompted the tax authorities to issue multiple clarifications and warnings to ensure compliance.
Furthermore, the manual submission of refund claims along with supporting documentation adds to the administrative burden on UIN holders.
Addressing these challenges requires continuous outreach, education, and cooperation between tax authorities, UIN holders, and suppliers.
Importance of Accurate Documentation for Refund Processing
The success of refund claims under UIN depends heavily on the accuracy and completeness of the documentation submitted.
Detailed invoice statements listing all purchases subject to GST are fundamental. These invoices must indicate the UIN of the recipient to qualify for a refund.
Certificates confirming the receipt of goods or services, along with other supporting evidence, are necessary to validate the claim.
The letter of reciprocity from the Ministry of External Affairs must be valid and accompany each refund application.
Bank account details must be precise, with a canceled cheque submitted along with the first refund claim to ensure correct crediting of funds.
Careful preparation and submission of these documents minimize the risk of delays or rejections in refund processing.
Enforcement and Penalties Related to UIN Non-Compliance
The government has put in place enforcement mechanisms to ensure compliance with GST requirements related to UIN. Suppliers who fail to record the UIN of the recipient on tax invoices may be subject to action under the GST law.
Such non-compliance can lead to penalties, notices, and other administrative actions against the supplier or vendor. The authorities take these violations seriously because failure to mention UIN hampers the refund process for foreign missions and international organizations.
To encourage compliance, the government has issued multiple circulars reminding suppliers of their obligations and warning of consequences for non-adherence.
Maintaining accurate tax invoices with the correct UIN is not only a legal requirement but also essential for fostering trust and cooperation between suppliers and UIN holders.
Benefits of UIN to Foreign Missions and International Organizations
The Unique Identity Number system under GST provides important benefits to foreign missions, United Nations agencies, and other eligible entities.
It allows these entities to claim refunds of GST paid on goods and services procured in India, thereby ensuring that the tax does not become a cost to them.
The centralized UIN facility simplifies compliance by allowing a single UIN to be used nationwide, reducing the need for multiple registrations.
The refund mechanism supported by UIN helps maintain the principle of tax neutrality for these special classes of persons, aligning with international diplomatic norms.
Overall, UIN facilitates ease of doing business for international entities operating in India and supports India’s commitment to international agreements on privileges and immunities.
Recent Developments and Clarifications
Over time, the tax authorities have issued various clarifications and circulars to address practical issues faced by UIN holders and their suppliers. These interventions have been essential in ensuring that the system remains functional, responsive, and user-friendly. For example, the waivers on the requirement to mention UIN on invoices during certain specified periods provided temporary relief and flexibility for suppliers struggling with system limitations or administrative challenges. Such relaxations demonstrated that the authorities are willing to accommodate genuine difficulties faced by taxpayers, especially when these are linked to technical glitches or changes in procedural requirements.
Circulars have also clarified procedural aspects such as the filing of Forms GSTR-11 and GST RFD-10 only for quarters where refund claims are filed. This significantly reduces unnecessary compliance burden, particularly for entities that may not have taxable transactions in every quarter but still maintain their UIN registrations for occasional transactions. By aligning the filing requirements with actual refund claims, the government has cut down on redundant submissions, enabling both taxpayers and the administration to focus resources where they are truly needed.
Another important measure has been the publication of the list of designated Central Tax nodal officers for receiving manual refund applications. This list provides clarity to UIN holders on where to submit their claims in cases where the online system cannot be used or when manual intervention is required for verification. Having a dedicated contact point helps prevent confusion, ensures accountability, and shortens the processing time for refunds.
In addition, periodic FAQs and updates issued by the GST Council and the Central Board of Indirect Taxes and Customs (CBIC) have provided step-by-step explanations of the refund process, documentation requirements, timelines, and possible reasons for rejection. These resources not only assist foreign missions and international organizations in fulfilling their compliance obligations but also help their suppliers understand the importance of accurate invoicing and record maintenance.
The government’s approach to refining the UIN system has shown a clear intent to align domestic GST procedures with international conventions and treaty obligations. By improving operational clarity, ensuring faster processing of refunds, and simplifying procedural requirements, the authorities have enhanced the credibility and efficiency of the system.
Going forward, further integration of UIN refund processes with automated GST systems, enhanced tracking mechanisms, and dedicated helpdesks could make the system even more robust. Continuous engagement between government bodies, foreign missions, and international organizations will be key to addressing emerging challenges and ensuring that India remains compliant with its international commitments while upholding the integrity of its GST framework.
Conclusion
The Unique Identity Number (UIN) under the Goods and Services Tax (GST) framework is an important provision designed to accommodate the special status of certain entities in line with international obligations. It is primarily granted to foreign diplomatic missions, consular posts, United Nations organizations, and other bodies or agencies that are notified by the Government of India. These entities often enjoy immunity from local taxes under international treaties, conventions, or bilateral agreements. The UIN mechanism enables them to claim refunds on GST paid on goods and services procured in India, thereby ensuring compliance with these global commitments while maintaining the integrity of the domestic tax system.
The issuance of a UIN provides a standardized and centralized means of identification for eligible organizations. This not only facilitates a smoother refund process but also minimizes the scope for administrative errors or disputes. The GST Council and the Central Board of Indirect Taxes and Customs (CBIC) have issued multiple notifications and clarifications to simplify the process, reduce delays, and ensure transparency. For example, UIN holders are generally required to file refund applications in a prescribed format, accompanied by supporting documents such as purchase invoices, payment proofs, and declarations. The refunds are typically granted after verification, ensuring that only legitimate claims are processed.
Suppliers and service providers who deal with UIN holders also have specific responsibilities. They must ensure that the UIN is correctly mentioned on tax invoices at the time of supply. This step is crucial because any omission or error can lead to rejection or delay of refund claims by the UIN holder. For vendors, failure to comply with this requirement can attract enforcement actions, including penalties under the GST law. Hence, awareness and proper training of accounting staff are essential when dealing with such transactions.
The periodic clarifications issued by the government have made the UIN system more user-friendly. In many cases, online tools and the GST portal facilitate the tracking and filing of refund applications, reducing paperwork and enhancing efficiency. However, despite these improvements, timely filing and accuracy in documentation remain critical for successful refund claims.