Section 39 provides that “relevant contributions”, for the purposes of sections 37 and 38, includes both contributions payable directly by an employer into a scheme and contributions payable by an employer on behalf of a worker out of deductions from the worker’s earnings.  The section also provides that the definition applies for both jobholders and for workers without qualifying earnings under section 9.
Commentary on Sections PART 1 – Pension Scheme Membership for Jobholders CHAPTER 2 – Compliance Section 39: Meaning of “relevant contributions”