On 8 January 2013, the Indian High Court issued its decision in the case of DIT v. Chiron Bearing Gmbh & Co. (ITA No. 2273/2010) that a limited partnership that pays trade tax and has a tax residency certificate will be eligible to the benefits under the Germany - India Income and Capital Tax Treaty (Tax Treaty). (a) Facts. The Taxpayer (i.e. Chiron Bearing Gmbh & Co.) received royalty and fees for technical services rendered in India. This income was subject to a lower withholding tax rate of 10% of the gross amount in accordance with article 12 of the Tax Treaty. However,...