Cite as: 511 U. S. 641 (1994)
Opinion of the Court
of Environmental Quality of Ore., ante, at 98; New Energy Co. of Ind. v. Limbach, 486 U. S. 269, 273 (1988). The Clause prohibits economic protectionism—that is, "regulatory measures designed to benefit in-state economic interests by burdening out-of-state competitors." Id., at 273-274. Thus, we have characterized the fundamental command of the Clause as being that "a State may not tax a transaction or incident more heavily when it crosses state lines than when it occurs entirely within the State," Armco Inc. v. Hardesty, 467 U. S. 638, 642 (1984), and have applied a "virtually per se rule of invalidity" to provisions that patently discriminate against interstate trade, Philadelphia v. New Jersey, 437 U. S. 617, 624 (1978).
A
By its terms, the additional use tax at issue in this case appears to violate the Commerce Clause's cardinal rule of nondiscrimination, for it exempts from its scope all sales of goods occurring within the State. See n. 2, supra. Nevertheless, our cases establish that such a levy may be saved from constitutional infirmity if it is a valid "compensatory tax" designed simply to make interstate commerce bear a burden already borne by intrastate commerce. Under the compensatory tax doctrine, a facially discriminatory tax that imposes on interstate commerce the equivalent of an "identifiable and substantially similar tax on intrastate commerce does not offend the negative Commerce Clause." Oregon Waste, ante, at 103 (internal quotation marks omitted). To ensure that the State is indeed merely imposing countervailing burdens on comparable transactions, we have required that the taxes on interstate and intrastate commerce be imposed on "substantially equivalent event[s]." Maryland v. Louisiana, 451 U. S. 725, 759 (1981). See also Armco, supra, at 643. The end result under the theory of the compensatory tax is that, "[w]hen the account is made up, the stranger from afar is subject to no greater burdens . . . than the dweller within the gates. The one pays upon one activ-
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