With play partners, whatever makes the ‘lee feel most ticklish, or mist comfortable. Some women I’ve known have gotten excited about being naked and vulnerable, others have felt a little safer with a bit more coverage.
I've always liked to start out with them fully clothed, shoes and all. That way I can "unwrap" my present as needed for tickling! Gives them a false sense of security until I start removing things like footware or a shirt for access to ticklish bare skin! They're tied up, of course!
I prefer a session to begin clothed, although if the girl wants to end up naked, That is fine, often as part of a piece by piece strip as the session goes along.
Oddly, I like when the lee starts out clothed.... there's a certain thrill to accelerating from tickling palms to forearms to armpits vs just having it all laid out. IDK. just me.