When “DI” Is Not Enough: Marking Accounting Notes for Indirect Discounts in JPK_VAT

• Both markers, not one. For accounting notes documenting indirect (bonus) discounts, using the “DI” designation alone is incorrect. According to Marcin Mroziuk (Dziennik Gazeta Prawna), the correct approach requires both the “DI” and the “WEW” designations in the evidence part of JPK_VAT. [edgp.gazetaprawna.pl], [edgp.gazetaprawna.pl]
• Why “DI” applies. From 1 February 2026, the JPK_V7(3) scheme requires every purchase and sales entry to carry either a KSeF number or a substitute marker. “DI” (dowód inny niż faktura) is the marker for documents other than an invoice — which is exactly what a debit or credit accounting note is. [vatupdate.com], [poradnikpr…ebiorcy.pl]
• Why “WEW” is also needed. Because the leasing company reduces its purchase value and input tax on the basis of the received note through an internal document entry, the “WEW” (internal document) marker must be applied alongside “DI”. The two markers describe different attributes of the same booking and are not mutually exclusive. [edgp.gazetaprawna.pl], [vatupdate.com]

1. The Question

A company providing car leasing services receives bonuses from dealers, the amount of which depends on the number and value of items purchased from them. For VAT purposes these are indirect discounts (rabaty pośrednie), documented either by the company through debit accounting notes or by the importer paying the discount through a credit note. The indirect discount amounts include VAT. On the basis of the notes received, the company reduces the value of its purchases and the input tax in the JPK_VAT for the period in which the discount amount was received. The question: should only the “DI” designation be used for these accounting notes? [edgp.gazetaprawna.pl] 

2. The Answer

No. For such accounting notes, both the “DI” and the “WEW” designations must be applied — not “DI” alone. [edgp.gazetaprawna.pl]

3. Background — the New JPK_V7(3) Markers

3.1. Context

From 1 February 2026, taxpayers must use the new JPK_VAT scheme, which requires a mandatory identification for each document in both the sales and purchase records. Each invoice must carry its KSeF number if one has been assigned; where there is no KSeF number, a substitute code must be used. [vatupdate.com]

3.2. The substitute codes

• OFF — for invoices issued during an official KSeF system outage that do not yet have a KSeF number on the filing date. [vatupdate.com], [tpa-group.pl]
• BFK — for electronic or paper invoices issued outside KSeF (including foreign invoices). [vatupdate.com], [tpa-group.pl]
• DI (dowód inny niż faktura) — for documents other than an invoice, such as internal documents for transactions not evidenced by an invoice. [vatupdate.com], [poradnikpr…ebiorcy.pl]

4. Why Both Markers Apply

4.1. “DI” — a document other than an invoice

An accounting note (whether a debit note issued by the company or a credit note from the importer) is, by definition, not an invoice. It therefore falls squarely within the “DI” category — the marker reserved for documents other than invoices entered in the VAT records. [vatupdate.com], [poradnikpr…ebiorcy.pl]

4.2. “WEW” — the internal document dimension

The reduction of the purchase value and of the input tax is booked in JPK_VAT on the basis of an internal document posting for the period in which the discount was received. This internal-document character triggers the existing“WEW” designation. Because “DI” describes the type of external evidence and “WEW” describes the internal booking used to reflect it, the two markers coexist on the same record rather than replacing one another. [edgp.gazetaprawna.pl], [vatupdate.com]

5. Practical Takeaway

Taxpayers who apply only “DI” to indirect-discount accounting notes risk an incomplete evidence part of JPK_V7(3). The consistent treatment is to tag these notes with“DI” + “WEW” so that both the non-invoice nature of the document and the internal-document basis of the input-tax adjustment are correctly reflected. [edgp.gazetaprawna.pl]

Sources

• Marcin Mroziuk,“Jak należy oznaczać w JPK_VAT noty księgowe dotyczące rabatów pośrednich”, Dziennik Gazeta Prawna, 31 July 2026 — edgp.gazetaprawna.pl [edgp.gazetaprawna.pl]
• VATupdate — New JPK_VAT Codes Mandatory from February 2026: KSeF, OFF, BFK, and DI Explained [vatupdate.com]
• Poradnik Przedsiębiorcy — Symbol DI w pliku JPK_VAT – kiedy należy go stosować? [poradnikpr…ebiorcy.pl]
• TPA Poland — Znaczniki NrKSeF, OFF, BFK i DI w JPK_VAT [tpa-group.pl]