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[[Taxes - Pledge GMSLA Provision|Sole]] difference between the {{gmsla}} and {{pgmsla}} is the removal in the pledge version of the lead-in reference in {{gmslaprov|12.1(d) | [[Taxes - Pledge GMSLA Provision|Sole]] difference between the {{gmsla}} and {{pgmsla}} is the removal in the pledge version of the lead-in reference in {{gmslaprov|12.1}}(d) “other than in respect of any payment made by {{pgmslaprov|Lender}} to {{pgmslaprov|Borrower}} under paragraph {{pgmslaprov|6.3}}...”. | ||
This is for the sensible reason that under the pledge structure the {{gmslaprov|Lender}} never holds the {{gmslaprov|Collateral}} — unless there’s an enforcement event — so is never required to manufacture income on it, since the {{gmslaprov|Borrower}} is holding it and gets the income directly. | This is for the sensible reason that under the pledge structure the {{gmslaprov|Lender}} never holds the {{gmslaprov|Collateral}} — unless there’s an enforcement event — so is never required to manufacture income on it, since the {{gmslaprov|Borrower}} is holding it and gets the income directly. |