Cite as: 514 U. S. 175 (1995)
Opinion of the Court
C
We now turn to the remaining two portions of Complete Auto's test, which require that the tax must "not discriminate against interstate commerce," and must be "fairly related to the services provided by the State." 430 U. S., at 279. Oklahoma's tax meets these demands.
A State may not "impose a tax which discriminates against interstate commerce . . . by providing a direct commercial advantage to local business." Northwestern States Portland Cement Co. v. Minnesota, 358 U. S., at 458; see also American Trucking Assns., Inc. v. Scheiner, 483 U. S. 266, 269 (1987). Thus, States are barred from discriminating against foreign enterprises competing with local businesses, see, e. g., id., at 286, and from discriminating against commercial activity occurring outside the taxing State, see, e. g., Boston Stock Exchange v. State Tax Comm'n, 429 U. S. 318 (1977). No argument has been made that Oklahoma disdence. Our decisions cannot be reconciled with the view that two taxes must inevitably be equated for purposes of constitutional analysis by virtue of the fact that both will ultimately be "pass[ed] . . . along to the customer" or calculated in a similar fashion, ibid. Indeed, were that to be the case, we could not, for example, dismiss successive taxation of the extraction, sale, and income from the sale of coal as consistent with the Commerce Clause's prohibition against multiple taxation.
Justice Breyer's opinion illuminates the difference between his view and our own in its suggestion, post, at 206, that our disagreement turns on differing assessments of the force of competing analogies. His analogy to Central Greyhound derives strength from characterizing the tax as falling on "interstate travel," post, at 207, or "transportation," post, at 202. Our analogy to prior cases on taxing sales of goods and services derives force from identifying the taxpayer in categorizing the tax and from the value of a uniform rule governing taxation on the occasion of what is generally understood as a sales transaction. The significance of the taxpayer's identity is, indeed, central to the Court's longstanding recognition of structural differences that permit successive taxation as an incident of multiple taxing jurisdictions. The decision today is only the latest example of such a recognition and brings us as close to simplicity as the conceptual distinction between sales and income taxation is likely to allow.
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