第2條
(a) Any pension (excluding a lump sum payment) paid by, or paid out of funds created or contributed by, the Government of a Contracting Party to an individual in respect of services rendered to that Party may be taxed in that Party. (b) Lump sums paid by, or paid out of funds created by, the Government of a Contracting Party to an individual in respect of services rendered to that Party shall be taxable only in that Party. (c) Lump sums paid under a mandatory provident fund scheme, and any other schemes or arrangements that may be established to replace the said scheme, shall be taxable only in the Hong Kong Special Administrative Region. (d) Notwithstanding the provisions of subparagraphs (a), (b) and (c) of this paragraph, if the individual who rendered the services is a resident of the other Contracting Party and the case falls within subparagraph (b) of paragraph 1 of this Article, any corresponding pension (whether a payment in lump sum or by instalments) shall be taxable only in that other Contracting Party.