Ina Ree­se Tax & Legal Prac­ti­ce – Flens­burg | Harrislee

Child benefit: Paramedic training does not count as initial training

BFH: The short para­me­dic trai­ning cour­se is not regard­ed as initi­al trai­ning – child bene­fit remains paya­ble despi­te full-time employment. 
Child benefit: Paramedic training does not count as initial training

Child benefit: Paramedic training does not count as initial training

Par­ents of child­ren who have rea­ched the age of majo­ri­ty are fami­li­ar with this pro­blem: at what point does entit­le­ment to child bene­fit cea­se when a child starts work after com­ple­ting their trai­ning? On 22 April 2026, the Fede­ral Fis­cal Court (BFH) han­ded down an important ruling on this mat­ter, which direct­ly affects fami­lies with child­ren working in the emer­gen­cy ser­vices (Ref.: III R 7/24).

What is child benefit after the end of a child’s education?

The Inco­me Tax Act distin­gu­is­hes bet­ween two situa­tions: if a child is still under­ta­king their first voca­tio­nal trai­ning or their first degree, they remain eli­gi­ble for child bene­fit, regard­less of how many hours they work along­side their stu­dies. Howe­ver, once they have com­ple­ted this initi­al trai­ning, child bene­fit is only paya­ble if the child works no more than 20 hours per week. This limit is cru­cial, as many young peo­p­le work full-time after com­ple­ting their trai­ning befo­re embar­king on fur­ther education.

The specific case: a daughter who is halfway through her paramedic training and her advanced paramedic training

In the case in ques­ti­on, a 21-year-old woman had com­ple­ted a trai­ning cour­se to beco­me a para­me­dic from Febru­ary to May 2023, fol­lo­wing her A‑levels and a peri­od of vol­un­t­a­ry ser­vice with the fede­ral govern­ment. This trai­ning com­pri­ses just 520 hours and takes around three months to com­ple­te on a full-time basis. She then work­ed full-time as a para­me­dic becau­se the fol­low-up trai­ning she had ori­gi­nal­ly plan­ned to under­ta­ke to beco­me an advan­ced para­me­dic could not begin until later.

The Fami­ly Bene­fits Office refu­sed to pay child bene­fit for the months of June to August 2023, arguing that the daughter’s initi­al edu­ca­ti­on had been com­ple­ted and that she was working more than 20 hours a week. The father took legal action against this decis­i­on; the Finan­ce Court ruled in his favour and the Fede­ral Fis­cal Court upheld this ruling.

The Federal Fiscal Court’s reasoning: a minimum period of one year

The Fede­ral Fis­cal Court (BFH) cla­ri­fied that trai­ning is only con­side­red to be initi­al voca­tio­nal trai­ning is dee­med to be within the mea­ning of the Act if it lasts for at least one year. The para­me­dic trai­ning does not meet this cri­ter­ion. Con­se­quent­ly, during the months in ques­ti­on, the daugh­ter had not yet com­ple­ted her initi­al voca­tio­nal trai­ning, even though she had alre­a­dy pas­sed the para­me­dic examination.

The entit­le­ment to child bene­fit the­r­e­fo­re remain­ed in force, even though the daugh­ter was working full-time. Her full-time employ­ment as a para­me­dic did not affect her entitlement.

Distinction: Paramedics should be assessed differently

The Fede­ral Fis­cal Court express­ly empha­sis­ed that trai­ning for the Para­me­dic Under the Para­me­dic Act, the full-time pro­gram­me lasts three years and thus con­sti­tu­tes initi­al voca­tio­nal trai­ning. Upon com­ple­ti­on of the pro­gram­me, the 20-hour limit would apply.

What does this mean for families?

This decis­i­on is of prac­ti­cal rele­van­ce to all par­ents who­se child­ren are com­ple­ting short trai­ning cour­ses in the emer­gen­cy ser­vices, the social sec­tor or other fields which, whilst useful for their future care­ers, last for less than a year. Such short-term trai­ning cour­ses do not ter­mi­na­te entit­le­ment to child bene­fit, pro­vi­ded the child sub­se­quent­ly intends to under­ta­ke fur­ther, lon­ger-term training.

In indi­vi­du­al cases, it is often dif­fi­cult to draw a clear distinc­tion. Anyo­ne who is unsu­re whe­ther their child’s edu­ca­ti­on meets the legal requi­re­ments should seek tax advice to avo­id the risk of having to repay any bene­fits to the fami­ly bene­fits office.

This artic­le was crea­ted with the help of AI and has been edi­to­ri­al­ly reviewed.

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