Depends a lot on the cards width, the motherboard's PCIe slot arrangement, and overall case cooling. Really have to get the heated air out of the case since the axial cards don't do it.
Standard 2x SLI and Crossfire boards have three slot spacing between the required slots. This leaves a gap between the cards. As long as the shrouds on the cards are tight enough against the card to prevent them from throwing air directly out of the side, then air flow can get to them.
When it isn't perfect you get an air cushion effect that actually insulates the cards, causing recirculation of the heated air and rapid overheating. Most of the axial cards today don't seem to have this problem. They are either very long, or have nice solid shrouds like the ACX 2.0 coolers. Vented shrouds, vents on the side, seem to perform the worst.
When you are talking about packing cards right next to each other, then the blower style cards are best. (Micro ATX SLI, or Tri SLI on an ATX board)