Ideally before the cat but as long as your aware of the difference a Cat makes to the AFR numbers (google it if not) then its ok after the cat and tune accordingly, i know many tune with a tailpipe clamped wideband (so well after the cat) and while not ideal it can be done effectively if you fully aware of how thing are affected doing so, a lot depends how close to the limits you want to get as well, closer you get to the limits the more accurate the data you need to be safe, so before cat AFR and EGT monitoring etc is best but for milder tuning not essential.