I guess the angle is that there was a style of SOAP where the payload was interpreted as a remote procedure call conforming to an interface described in a WSDL document.
So there would be a SOAP library or server infrastructure (BizTalk) on the receiving end that would decode the message and turn it into a function call in some programming language.
In that sense, the payload would be "data" only for the infrastructure code but not on the application level.
And now I'm going to have to spend the rest of the day trying to forget this again :)
Most implementations don't retrieve parameters by tag, they retrieve parameters by order, even if that means the tags don't match at all. This is completely unlike JSON.
Also, almost nobody uses REST, so stop calling things REST, when you are talking about HTTP APIs.