No, I wouldn't call that sideloading. Maybe... Depends on exactly what you mean. Choking a stem by running your lanyard around it and clipping in to the standing part would be a classic example of side loading. The rope is connected to the biner at each each end, but the applied force is 90° to the vertical axis of the spine.
Another example would be a biner partially cantilevered over a limb. Maybe you're clipped into a sling, working around the tree, and the biner ends up on top of a limb, where it's tethered on the X axis, but half the biner is having force applied to the Y axis.
If you're just hanging in the tree, and the biner's forced up against the stem, that wouldn't be sideloading unless something crazy was going on in a failure situation.