High potential
I'm afraid the answer is yes. The 'rate' at which torque is converted into tension in a nut/bolt assembly is dependent upon the friction on mating surfaces. If the bolt head is held immobile while the nut is tightened (the ideal, design case)then the mating surface area on the substrate under the nut will be the determining area. If, on the other hand, bolt head is turned and nut is immobilised, the mating surface area under bolt head will determine installed tension in the bolt. If these two mating areas happen to be equal, then there is effectively no difference in recommended torquing values if torque is applied to bolt head or nut.
Another consideration is nut shape. Some nuts, particularly self-locking nuts, will deform when torque is applied. The torque applied to the nut when following torque recommendations by turning the nut, is not the same as the torque required to stop rotation of the nut when this same recommended torque is applied to bolt head. The resulting nut deformation will not be the same and this in turn will affect the friction coefficient of the thread mating surfaces. For regular hexagonal nuts however, nut deformation would be nil.