NEC 210.52(C)1-5 A receptacle outlet shall be installed at each counter space 12-inches or wider and at each island counter or peninsular space greater than 24-inches by 12-inches. Receptacles shall be located not more than 20-inches above the countertop, or not more than 12-inches below the countertop and must not be located below a countertop overhang greater than 6 inches.
I would think that this refers to requirement outlets serving the countertop, and not requirements for outlet requirements for a wall. I would think that an outlet in your counter at the same height as your wall outlets would be a good place to plug in a vacuum cleaner etc. And thus might let you have one less outlet on the outside wall. Another option would be to use a floor outlet.
But I am not sure. I am not an electrician. If the section I cited above is not the one you are referring to, what are you referring to?