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Done it both ways on two sets of rims/wheels. It works both ways, and depends on your approach. With the tire off, it's a good opportunity to thoughly clean up the rust and grind or wire brush them clean and then prime to help protect from further rust. With tires remove and with a hardened paint or standard rattle can paint it won't matter, a small amount of chipping or scratching will occur. Not enough to think twice about. On the 9N I was more thorough than the 850 and chose to remove the tires, and sandblast, etch, and POR 15 the rims and painted then painted over the exteriors. That should protect them from rusting out over the years, as well prior to all that I dipped them in a kiddy pool of phosphoric acid to neutralize the rust on the inside of the 32" rims (if there was any). Touching up after mounting was a minor job. I found that painting with the tire on a minor hassle, more in line with cleaning up the rubber from overspray. But not enough to be a pain...
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