In United Services Automobile Association v. Commonwealth, 152 Pa. Commw. 184, 618 A.2d 1155 (Pa. Cmwlth. 1992) (USAA), a Texas insurance company challenged its retaliatory tax assessment. While Pennsylvania has a flat 2% premium tax rate, Texas, like New Jersey here, has certain conditions or exemptions that may impact the ultimate premium tax amount a Pennsylvania company would pay in Texas. Texas law provides a tiered rate structure. The default premium tax rate is 3.5% of Texas premium--1.5% greater than Pennsylvania's 2.0% rate. If, however, an insurance company makes certain investments in Texas, defined as "Texas investments," the company would qualify for a lower premium tax rate--2.4% or 1.2%, depending on the level of its "Texas investments." USAA, 618 A.2d at 1157. The question before the Court in USAA was whether calculation of the retaliatory tax due under Section 212 of the Act requires only a state-by-state comparison of premium tax rates in Texas and Pennsylvania, or, instead, whether it requires a company-by-company comparison to determine what a "like company of this Commonwealth" would pay in premium tax in Texas. The Court concluded that the express terms of Section 212 of the Act require a company-by-company approach. In reaching this conclusion, we relied on the following statutory language: "'In applying this section to an insurance company of another state, such company shall not be required to pay any taxes and fees which are greater in aggregate amount than those which would be imposed . . . upon a like company of this Commonwealth transacting the same volume and kind of business in such other state.'" USAA, 618 A.2d at 1158 (emphasis in original) (quoting 40 P.S. 50). Finding that a Pennsylvania company transacting business in Texas with investments at a similar level to USAA would pay premium tax at Texas's lowest 1.2% tax rate, this Court reversed the Board's imposition of a retaliatory tax on the Texas insurance company. Id. at 1160.