A court cannot appoint a receiver to wind up a private trust merely because of a breakdown in mutual trust and confidence between unit holders; the Ebrahimi principle is confined to the statutory power to wind up companies and does not extend to trusts. Parties who choose a trust structure for tax advantages must accept the legal consequences, including the absence of winding-up mechanisms available for companies or partnerships. The oppression provisions of the Corporations Act apply to corporate trustees, but mere deadlock or disagreement does not constitute oppression.
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