Split beam it still matters (see ronkz650's post above). AFAIK the only torque wrenches that it would not matter are those where the torque sensing mechanism is directly in line with the square drive, and the only ones I know like that are dial-type like this:The explanation in the video "clicked" for me and with this style of wrench I would agree that position matters.
In my mind I was thinking more of a split beam style wrench. But now I'm questioning as to whether the split beam would also have hand position matter?
I think the beam parts in the split beam are tangent to the rotating part and may not be hand sensitive.

These have a "weak area" behind the square drive that is designed to flex a little to give the torque reading.
There may be others where hand position does not matter.