税收法治是一个超越税收的概念,是以税收立法权、行政权、司法权的相互独立与制约,特别是税收司法权对税收行政权的监督保障为基础的。从法律适用角度而言,司法机关也是税法适用的主体。在税收法治的进程中,税收行政与税收司法能否在统一的税收法律价值观的支配下,相互协调配合,发挥税收司法的监督保障作用,是一个关键问题。本文试图从税收实践出发,对税收行政与税收司法协调中的几个突出问题做一剖析,以期对实践中的问题有所反思,对完善两者的衔接有所裨益。 Tax law is a concept that surpasses taxation. It is based on the independence and restriction of tax legislative power, executive power and judicial power, especially the supervision and administration of tax judicial power over tax administrative power. From the perspective of the application of law, the judiciary is also the subject of tax law. In the process of tax law and rule, whether the tax administration and tax administration can coordinate and cooperate with each other under the control of the unified legal value of tax law and play the role of supervision and guarantee of tax administration is a key issue. This paper tries to analyze the several prominent problems in tax administration and tax administration coordination from the tax practice, in order to reflect on the problems in practice and to improve the connection between the two.