ISLA publishes updated UK Tax Addendum
25 February 2026 UK
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The International Securities Lending Association (ISLA) has published an updated UK tax addendum, available to all members of the association.
The 2026 version updates the 2014 UK Tax Addendum for the Global Master Securities Lending Agreement (GMSLA) (2010), and has been developed with ADE Tax and the ISLA Legal Steering and Tax working groups.
Now simplified and updated, the 2026 addendum is available for use where a borrower under, either the GMSLA 2010 or the GMSLA Pledge 2018, or a lender, in the case of non-cash collateral transferred by borrower to lender pursuant to the GMSLA 2010, may be required to withhold tax from manufactured payments to a lender (or borrower, as the case may be) relating to Net Paying UK Securities (as defined in the addendum).
Tina Baker, head of legal services, at ISLA, states: “With ever evolving tax rules, providing our members with clarity and certainty has been an important priority of ISLA and the ISLA Legal Steering and Tax working groups.
“This publication not only provides that, but is also testament to the collaborative efforts across our member firms and working groups.”
Martin Walker, principal, at ADE Tax, adds: “I hope that borrowers and lenders alike will find ISLA's updated UK Tax Addendum fair, clear, and simple to use, whether collateral is being transferred outright or pledged, as well as capable of accommodating the idiosyncrasies of UK withholding tax rules.”
The 2026 version updates the 2014 UK Tax Addendum for the Global Master Securities Lending Agreement (GMSLA) (2010), and has been developed with ADE Tax and the ISLA Legal Steering and Tax working groups.
Now simplified and updated, the 2026 addendum is available for use where a borrower under, either the GMSLA 2010 or the GMSLA Pledge 2018, or a lender, in the case of non-cash collateral transferred by borrower to lender pursuant to the GMSLA 2010, may be required to withhold tax from manufactured payments to a lender (or borrower, as the case may be) relating to Net Paying UK Securities (as defined in the addendum).
Tina Baker, head of legal services, at ISLA, states: “With ever evolving tax rules, providing our members with clarity and certainty has been an important priority of ISLA and the ISLA Legal Steering and Tax working groups.
“This publication not only provides that, but is also testament to the collaborative efforts across our member firms and working groups.”
Martin Walker, principal, at ADE Tax, adds: “I hope that borrowers and lenders alike will find ISLA's updated UK Tax Addendum fair, clear, and simple to use, whether collateral is being transferred outright or pledged, as well as capable of accommodating the idiosyncrasies of UK withholding tax rules.”
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