粤港澳大湾区作为中国国内经济发展的关键区域，维护区域内安全稳定的环境以支撑经济发展的可持续性实属必要，其跨境治安合作已成为重要议题。缓刑犯的独特性使其在异地接受刑罚时不可避免地需要面临比其他被判刑人更为窘迫的处境，而基于粤港澳三地缓刑法律制度的相似性、合作起步时间早等原因，在粤港澳大湾区实行缓刑犯的移管已具备充分的可操作性。但是，由于内地法律对其他法域的刑事判决持有消极的态度，且香港、澳门两个特区有关刑事司法协助的法律都将内地排除在外，这些制度使得在粤港澳大湾区开展区际刑事司法互助合作举步不前。对此，本文通过梳理、对比我国理论界、实务界提出的区际刑事司法互助模式，指出与我国当前现状适配性最高的模式还是协议模式，并且从粤港澳大湾区缓刑犯移管合作入手可能面临的阻力应当是最小的，有助于实现区际刑事司法互助合作的突破性进展。除此之外，本研究还论述了与之相匹配的法律原则：一国两制原则、双重犯罪原则以及人权保障原则，以期该项合作能够有序发展。

As the Guangdong-Hong Kong-Macao Greater Bay Area (GBA in hereinafter) is a key area for China’s domestic economic development, it is necessary to maintain a safe and stable environment to support the sustainability of economic progress, and cross-border policing cooperation has become an essential issue. The distinctive features of probationers make it inevitable for them to face a more difficult situation than other sentenced persons when they receive their sentences in a remote place. Based on the similarity of the probation legal systems in GBA, as well as the early start of the criminal cooperation, the transfer of probationers in GBA is sufficiently practicable. However, due to the negative attitude of mainland laws towards criminal judgments of other jurisdictions, and the exclusion of the mainland from the laws on mutual legal assistance in criminal matters in the Hong Kong and Macao, these regulations have made it difficult for inter-regional mutual legal assistance in criminal matters to be carried out in the GBA. In this regard, this paper analyzes and compares the models of inter-regional mutual legal assistance in crimes proposed by China's theoretical and practical circles, and points out that the model with the highest adaptability to China's current situation is the Agreement Model, for which the possible resistance from the probationer transfer cooperation in GBA should be the smallest, which will help to achieve a breakthrough in the cooperation of inter-regional mutual legal assistance in criminal matters. In addition, this study also discusses the legal principles that accompany it: the principle of one country, two systems, the principle of double criminality, and the principle of human rights protection, with a view to the orderly development of this cooperation.