纳税人诉讼是一种以私权制约公权的公益诉讼。作为衡平法上的救济方式,它不仅在英美法系国家得到承认,而且也被一些大陆法系国家所接受,并得以发展。对纳税人诉讼制度的比较研究,可以为发挥公众在财政监督中的作用,增强宏观调控法的可诉性,推进我国公共财政体制以及民主法治建设提供有益的借鉴。 Taxpayer litigation is a kind of public interest litigation with private power restricting public power. As a method of equitable relief, it is not only recognized in common law countries but also accepted by some civil law countries and developed. A comparative study of the taxpayer litigation system can provide useful reference for the public to play its role in the financial supervision, enhance the suability of the macro-control law, promote the public financial system and the rule of law and democracy in our country.