19.Where property forming part of the estate of the deceased is situated in a foreign country and the Commissioner-General is satisfied that any duty is payable on the death of the deceased in that country in respect of that property he shall in determining the value of such property allow a deduction of an amount equal to
(a) the amount of the duty payable in that country; or |
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(b) such proportion of the estate duty payable under this Act upon the value of that estate as is equal to the proportion which the value of the property situated in that country bears to the value of the estate, |
| whichever amount is the lower. |