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Cite as: 546 U. S. 95 (2005)
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Syllabus 2. The Tenth Circuit erred in concluding that the Kansas tax is never theless subject to Bracker’s test. That test applies only where “a State asserts authority over the conduct of non-Indians engaging in activity on the reservation.” 448 U. S., at 144. It has never been applied where, as here, a state tax imposed on a non-Indian arises from a trans action occurring off the reservation. The Court’s Indian tax immunity cases counsel against such an application. Pp. 110–115. (a) Limiting the Bracker test exclusively to on-reservation transac tions between a nontribal entity and a tribe or tribal member is consist ent with this Court’s unique Indian tax immunity jurisprudence, which relies “heavily on the doctrine of tribal sovereignty [giving] state law ‘no role to play’ within a tribe’s territorial boundaries,” Oklahoma Tax Comm’n v. Sac and Fox Nation, 508 U. S. 114, 123–124. The Court has taken an altogether different course, by contrast, when a State asserts its taxing authority outside of Indian country. E. g., Chickasaw, supra. In such cases, “[a]bsent express federal law to the contrary, Indians going beyond reservation boundaries have generally been held subject to nondiscriminatory state law otherwise applicable to all citizens of the State.” Mescalero Apache Tribe v. Jones, 411 U. S. 145, 148–149. If a State may apply a nondiscriminatory tax to Indians who have gone be yond the reservation’s boundaries, it may also apply a nondiscriminatory tax where, as here, the tax is imposed on non-Indians as a result of an off-reservation transaction. In these circumstances, Bracker is inappli cable. Cf. Arizona Dept. of Revenue v. Blaze Constr. Co., 526 U. S. 32, 37. The application of the test here is also inconsistent with the Court’s efforts to establish “bright line standard[s]” in the tax administration context. Ibid. The Nation is not entitled to interest balancing by vir tue of its claim that the Kansas tax interferes with the Nation’s own motor fuel tax. This is ultimately a complaint about the state tax’s downstream economic consequences. The Nation cannot invalidate that tax by complaining about a decrease in its revenues. See, e. g., Wash ington v. Confederated Tribes of Colville Reservation, 447 U. S. 134, 156. Nor would the Court’s analysis change if legal significance were accorded the Nation’s decision to label a portion of its gas station’s reve nues as tax proceeds. See id., at 184, n. 9. Pp. 110–115. (b) This Court rejects the Nation’s contention that the Kansas tax is invalid notwithstanding the Bracker test’s inapplicability because it exempts from taxation fuel sold or delivered to state and federal sover eigns and is therefore impermissibly discriminatory. The Nation is not similarly situated to the exempted sovereigns. While Kansas’ tax pays for roads and bridges on the Nation’s reservation, including the main highway used by casino patrons, Kansas offers no such services to the
