© 2025 by Michael Firth KC, Gray's Inn Tax Chambers
Contact: michael.firth@taxbar.com

Importance and exclusivity (degrees of)
Specifically​​
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- Particularly, but not necessarily exclusively
"[269] The question asked is whether the chicken paper bags were "specifically designed" for hot food. "Specifically" is defined in the Oxford English Dictionary as meaning, among other things, "particularly; with a particular or clearly defined purpose, meaning etc". Whilst "specifically" requires a particular purpose, it does not carry any connotation of exclusivity. We consider that, if, looking at the characteristics of the chicken paper bags objectively, it would be reasonable to conclude that the packaging has been designed with hot food in mind, to address particular problems presented by hot food, then they can be said to have been specifically, albeit not exclusively, designed for hot food." ​(WM Morrison Supermarkets Ltd v. HMRC [2025] UKFTT 1542 (TC), Judge Baldwin)
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