How are pensions taxed under the Hong Kong-United States tax treaty?

Under the Hong Kong-United States tax treaty, private pensions are generally taxable only in the country of residence — meaning no withholding tax applies at source (0%). This is favorable for retirees who have moved between the two countries, as their pension income will not be subject to double taxation. Government pensions may have different rules under a separate treaty article. This 0% rate compares to a median of 0% across Hong Kong's 23 active treaty partners, and 0% across United States's 64 active partners.