Also conveyed were a letter from Accountant Be'eri dated 20/7/17 confirming that the dividends received in 2016 were reported to the authorities and tax was paid for them, a letter from Accountant Be'eri dated 5/9/17 detailing the dividends that Toledano received from Paragon E X over the years; A letter from Toledano dated July 23, 2017 with an explanation, supported by documents, of the question of why the dividend money was transferred from a German bank and the confirmation of the German bank supporting this (thus explaining that since the transfer is in dollars while the Paragon EX account operates in euros, the transfer is transmitted and paid for dollar payments through a third party - the German bank).
In addition, and with regard to the plaintiffs' customers, the certifications of the accountants of MPF (dated May 2, 2017), Realtenco (dated May 9, 2017) and UFX (dated June 21, 2017) were transferred [see Appendix 25 to Michal Alon's affidavit]. I note that I am unable to accept the bank's comment that the tax certificates that were transferred are not sufficient, since they specify that the client companies pay tax lawfully, while the bank also requests confirmation that tax was paid at source in respect of all the funds in the transferors' accounts - i.e., a certificate relating to withholding tax to the end customers of the plaintiffs' customers [see paragraph 39.2 of Lotem's affidavit and paragraph 15 of the bank's reply summaries]. With regard to this claim, first, it was clarified by the accountant of the client companies that such a document would not be produced in any way that is inconsistent with the rules that apply to the accounting firms accompanying the clients [see Appendix 26 to Mr. Michal's affidavit]. Moreover, I am of the opinion that this is a far-reaching approval, as to the theory and practice of its purpose also to clarify the payment of tax by the end customers - which in my view is unreasonable and exceeds a great deal from the investigations and demands that the bank is required to carry out in the framework of its duties.
- In addition, the suspicions regarding the end customers of the client companies were removed:
In this context, and with regard to the end customers of the plaintiffs' customers, a list of the countries of the end customers of all the customers was provided, and policy documents were provided of all the plaintiffs' customers, indicating that they are operating a "know the customer" policy, which is intended to remove these suspicions, as well as blocking the possibility of activity by someone who is a citizen of an enemy country.