The safe harbour provision was unpopular since the beginning of transfer pricing (TP) implementation in Indonesia, even though this provision has been well-known in several countries. Indonesia’s existing safe harbour provision has solely governed the threshold on TP documentation obligation that could not offer certainty about tax audit treatment. The TP threshold refers to the total transaction volume per fiscal year with an affiliation that allows taxpayers to get relief from submitting TP documentation. A deemed profit also applies to a certain manufacture contract. With current provisions, the TP burden of taxpayers and tax administration could not reduce because no certainty on the tax audit exemption with the existence of the threshold provision. Therefore, it needs to improve the safe harbour rule to enhance the certainty manufacturer and reduce the administrative burden. © 2021, Gadjah Mada University Faculty of Law. All rights reserved.