I'm left-handed and always tilt paper at least 45° clockwise, effectively writing from below. Never had any smudging issues, even with fountain pens, as my hand simply never goes over any ink. Left-handed people who write from above by bending their wrist have always confused me, as it's both less comfortable and does not completely avoid smudges.
You meant counterclockwise, I guess? Because clockwise would mean to write from above, not below?
Interested because my son is learning to write and is the only leftie in the family, so I struggle to help him.