The process of estimating and counting tree density using only a single aerial or satellite image is a difficult task in the fields of photogrammetry and remote sensing. However, it plays a crucial role in the management of forests. The huge variety of trees in varied topography severely hinders tree counting models to perform well. The purpose of this paper is to propose a framework that is learnt from the source domain with sufficient labeled trees and is adapted to the target domain with only a limited number of labeled trees. Our method, termed as AdaTreeFormer, contains one shared encoder with a hierarchical feature extraction scheme to extract robust features from the source and target domains. It also consists of three subnets: two for extracting self-domain attention maps from source and target domains respectively and one for extracting cross-domain attention maps. For the latter, an attention-to-adapt mechanism is introduced to distill relevant information from different domains while generating tree density maps; a hierarchical cross-domain feature alignment scheme is proposed that progressively aligns the features from the source and target domains. We also adopt adversarial learning into the framework to further reduce the gap between source and target domains. Our AdaTreeFormer is evaluated on six designed domain adaptation tasks using three tree counting datasets, ie Jiangsu, Yosemite, and London; and outperforms the state of the art methods significantly.