Before his passing, John (a South African resident) was married to Charmaine. They were married on 01 May 1995. They were married out of community of property with inclusion of the accrual system. John's estate consists of the following: 1. Primary residence in Cape Town: R7,000,000.00. This residence was purchased in 2002 for an amount of R1,500,000.00. There is an outstanding bond on the property of R1,000,000.00. 2. Apartment on the Isle of Man with a value of R8,000,000.00. This property was inherited from John's uncle, Raymond, in March 2004 when it had a value of R4,000,000.00. Raymond was a resident and citizen of the United Kingdom (UK) and was never a South African resident. There is no double tax agreement or double death duties agreement between the Republic of South Africa and the Isle of Man. You can assume that there will be no capital gains tax (CGT) payable in the Isle of Man and that the South African executor will deal with this property in the winding up of the estate. 3. A BMW, to the value of R500,000.00 (no debt outstanding). 4. His personal effects and household items amount to R1,500,000.00. 5. There are the following policies in his life (John is the contracting party on all the policies): 6. Life Insurance Policy A (pure risk) where there is no beneficiary nominated on the policy: R5,000,000.00. 7. Life Insurance Policy B where Charmaine is the beneficiary: R15,000,000.00. 8. Policy C where John and Charmaine's son, Joe, is the beneficiary: R10,000,000.00. Charmaine's estate consists of the following: 1. An Audi valued at R400,000.00, with outstanding debt of R100,000.00. 2. A holiday house in Hermanus, valued at R4,000,000.00. The holiday house was inherited from Charmaine's father when he passed away in 1992. There is no outstanding debt in respect of the holiday house. You can assume that the calculated value for CGT purposes on 01 October 2001 was R1,500,000.00. 3. Her personal effects and household items amount to R1,500,000.00. 4. She is the contracting party on an endowment policy. The policy has a cash value of R600,000.00 and the insured value is R1,000,000.00 (Charmaine is the life insured on the policy). 5. She is also the contracting party and life insured on a life insurance policy (pure risk policy), with an insured value of R3,000,000.00. There is no beneficiary nominated on the policy. 6. She has R450,000.00 in the bank. These funds emanate from a claim for non-patrimonial damage paid to Charmaine by the road accident fund as a result of injuries she sustained in a motor vehicle accident. John passed away on 07 February 2023. The relevant portions of his will provide the following: 1. The property on the Isle of Man is bequeathed to an offshore trust. The trust is a discretionary trust. The will provides that the trustees can, at their discretion, award any rental income of the property to Charmaine and Joe. John was 65 years of age when he passed away and Charmaine was 59 years of age at the time of his passing. 2. Charmaine inherits the residue of his estate. You can assume the following: (i) The executor is entitled to the maximum allowable remuneration and value-added tax (VAT) is payable on the executor's fees. (ii) The balance of administration costs and last expenses (including funeral costs but excluding Master's Fees) amount to R80,000.00. (iii) John pays tax at a marginal rate of 45%. The antenuptial contract between John and Charmaine provides an inception value of R500,000.00 in respect of both John's estate and Charmaine's estate. The CPI headline index number on the date when John and Charmaine were married was 23.2 and on the date of John's passing it was 107.9. Calculate the estate duty liability in John's estate