比较法一直占据冲突法研究的主导地位,但比较法不能为冲突法提供普遍原则和共同标准,在理论和实践上均有局限性。库恩的范式理论可以与冲突法理论相结合。从历史上看,萨维尼的“法律关系本座说”是最具范式特征的理论,它有自己的哲学前提和价值取向,并以“本座”为基本概念构成了相对完整的理论范式。随着当下国际社会、经济关系的深刻变化,以萨维尼为代表的传统冲突法范式面临多种危机,预示着新的冲突法革命的到来。 The comparative law has always occupied the leading position in the study of conflict law. However, the comparative law can not provide general principles and common standards for conflict of laws, which have limitations in theory and practice. Kuhn’s paradigm theory can be combined with the theory of conflict law. Historically, Savigny’s theory of the relationship between the seat and the seat is the most paradigmatic one. It has its own philosophical premise and value orientation and constitutes a relative completeness based on the basic concept of “seat” Theoretical paradigm. With the profound changes in the current international community and economic relations, the traditional paradigm of conflict of laws represented by Savigny faces a variety of crises, which indicates the arrival of a new law of conflict.