Multinational Enterprises have become a main driver in the creation of international tax administration, and the relationship between MNEs and the international cooperation on tax administration can be viewed in two dimensions. on the one hand, MNEs are the most important regulation object of the international cooperation on tax administration. On the other hand , MNEs are a driving force of the creation, challenges, changes and developments of the international tax cooperation on tax administration. As a result, the relationship between MNEs and the international tax cooperation on tax administration should be realized in a two-fold transitions: the first one is the attitude aspect, which requires the transition from confrontation and passive obedience stage to voluntary compliance stage. While the second aspect lies in MNEs’ status, which requires the transition from the regulation object to aparticipant of the international tax cooperation on tax administration. This subject has attracted the international community’s attention, and a lot of further investigations and legal practices have been conducted recently. China should also make a passive response through such measures as to strength the dialogue and cooperation with MNE taxpayers, to provide tailor-made taxation services, and to build risk feedback mechanism for large taxpayers.