New York Consolidated Laws, Tax Law - TAX § 1177. Limited binding and beneficial effect

(a) The agreement authorized by this article binds and inures only to the benefit of New York state and the other member states.  No person, other than a member state, is an intended beneficiary of the agreement.  Any benefit to a person other than a state is established by the laws of New York state and the other member states and not by the terms of the agreement.

(b) Consistent with subdivision (a) of this section, no person shall have any cause of action or defense under the agreement or by virtue of New York state's approval of the agreement.  No person may challenge, in any action brought under any provision of law, any action or inaction by any department, agency, or other instrumentality of New York state, or any political subdivision of New York state on the ground that the action or inaction is inconsistent with the agreement.

(c) No law of New York state, or the application thereof, may be declared invalid as to any person or circumstance on the ground that the provision or application is inconsistent with the agreement.