N.Y. Tax Law § 1177

§ 1177. Limited binding and beneficial effect. (a) The agreement\nauthorized by this article binds and inures only to the benefit of New\nYork state and the other member states. No person, other than a member\nstate, is an intended beneficiary of the agreement. Any benefit to a\nperson other than a state is established by the laws of New York state\nand the other member states and not by the terms of the agreement.\n (b) Consistent with subdivision (a) of this section, no person shall\nhave any cause of action or defense under the agreement or by virtue of\nNew York state's approval of the agreement. No person may challenge, in\nany action brought under any provision of law, any action or inaction by\nany department, agency, or other instrumentality of New York state, or\nany political subdivision of New York state on the ground that the\naction or inaction is inconsistent with the agreement.\n (c) No law of New York state, or the application thereof, may be\ndeclared invalid as to any person or circumstance on the ground that the\nprovision or application is inconsistent with the agreement.\n