Anyone wishing to claim child benefit for their child who has reached the age of majority needs to be aware of a number of rules. One of these concerns what is known as ‘initial education’. The Federal Fiscal Court (BFH) has now clarified in a recent ruling that training to become a paramedic does not count as completed initial education within the meaning of the Income Tax Act. The result: child benefit must continue to be paid even if the child subsequently works full-time as a paramedic.
What does the term ‘initial training’ mean?
Child benefit for children who have reached the age of majority is subject to certain conditions. As long as a child is undertaking their first vocational training or their first degree, it does not matter how many hours they work alongside their studies. The situation is different once the initial training has been completed. From that point onwards, entitlement to child benefit ceases if the child works more than 20 hours a week. This provision is set out in Section 32(4) of the Income Tax Act.
The key issue, therefore, is which qualifications count as initial training and which do not. This was precisely the subject of the case before the Federal Fiscal Court.
The case: Daughter worked full-time after completing her paramedic training
The claimant’s 21-year-old daughter had completed a training course to become a paramedic from February to May 2023, following her A‑levels and her Federal Voluntary Service. As her originally planned vocational training could not yet begin, she subsequently took up a full-time position as a paramedic. For the months of June to August 2023, the family benefits office refused to pay child benefit on the grounds that her initial training had already been completed.
The Finance Court ruled in the father’s favour, and the Federal Fiscal Court has now upheld this ruling on appeal.
BFH: A minimum duration of one year is required
The Federal Fiscal Court (BFH) clarified that a training course is only regarded as a completed initial training course if it lasts at least one year. The paramedic training course comprises just 520 hours and takes around three months to complete on a full-time basis. It therefore does not meet this minimum requirement.
The court expressly emphasised that the training does indeed lead to professional qualification, i.e. it enables the holder to practise a recognised profession. However, that alone is not sufficient to count the initial training as having been completed for tax purposes. If this were not the case, even very short training courses could result in parents losing their entitlement to child benefit for a child who is actually still at the very beginning of their educational journey.
By way of comparison, the Federal Fiscal Court cited the training programme for paramedics. Under the Paramedics Act, this programme lasts three years on a full-time basis and would therefore be regarded as initial training.
What does this mean for parents?
The ruling is relevant to parents whose children, after leaving school, first undertake shorter training courses before beginning their actual vocational training. Such transitional periods do not automatically result in the loss of child benefit, even if the child works full-time during this period.
- Child benefit continues to be paid as long as the child has not completed their initial education.
- A training course is only regarded as initial training if it lasts at least one year.
- Short-term qualifications, such as paramedic training, are not included.
Whether the rule applies in a particular case depends on the exact circumstances. Parents who are unsure whether their claim for child benefit has been rightly rejected should seek legal advice.
Federal Fiscal Court (BFH), judgement of 22 April 2026, case number III R 7/24, published on 30 July 2026
Source: Haufe: Tax
This article was created with the help of AI and has been editorially reviewed.
