Yes, it is always the outer top edge of the tire that rubs for me, so I would assume if that was closer to the hub then it probably wouldn't rub. So either 9 inch rims instead of 10, or simply 10 inch wide instead of 12 inch wide tiresI've seen people run 35's without rubbing. A lot it is based on the actual tire. When you compare two tires side by side, even though you might be comparing the same size, the shoulder of the tire is shaped different. Some rub while some don't.