Cite as: 511 U. S. 641 (1994)
Opinion of the Court
regulating intrastate and interstate commerce, as long as it is not translated into any difference in the substance of regulations imposed, cannot be said to provide "benefit[s]" to intrastate commerce or to impose discriminatory "burden[s]" on interstate trade. New Energy, 486 U. S., at 273. Thus, it would not violate the Commerce Clause.
For similar reasons, the mere fact that determining the compensatory character of the use tax in this case requires consideration of the sales taxes levied by hundreds of local jurisdictions does not mean that the use tax should be rejected in toto as facially discriminatory. A compensatory tax and the tax for which it compensates need not be promulgated in the same provision of state law, or even through the same governmental entity, to survive Commerce Clause scrutiny. Such matters of form do not determine in substance whether the tax merely requires interstate commerce to "pay its way," Complete Auto Transit, Inc. v. Brady, 430 U. S. 274, 281 (1977) (internal quotation marks omitted), or discriminates against interstate trade. "The question of constitutional validity is not to be determined by artificial standards. What is required is that state action, whether through one agency or another, or through one enactment or more than one, shall be consistent with the restrictions of the Federal Constitution. There is no demand in that Constitution that the State shall put its requirements in any one statute. It may distribute them as it sees fit, if the result, taken in its totality, is within the State's constitutional power." Gregg Dyeing, supra, at 480. See also Maryland, 451 U. S., at 756; Halliburton, supra, at 69.5 If a State may
5 Of course, this is not to suggest that courts should "plunge . . . into the morass of weighing comparative tax burdens," American Trucking Assns., Inc. v. Scheiner, 483 U. S. 266, 289 (1987) (internal quotation marks omitted). But as far as the compensatory tax doctrine is concerned, a court that is confined to examining the rates specified in statutes, ordinances, or regulations for taxes assessed on "substantially equivalent event[s]," Maryland v. Louisiana, 451 U. S. 725, 759 (1981)—even if the
655
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