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Chapter 8: Playing the Game / Movement / Cover / Special Circumstances

3D Flanking

Source Player Core pg. 425 2.0
Though battle grids are often two-dimensional, the game world isn't! Sometimes you might need to visualize a creature's space as a cube for flanking. For instance, if Valeros is underneath a flying sphinx while Lini is flying above the sphinx, they might be flanking it even if they're piled in an odd stack on your battle grid. And if Valeros were mounted on a horse, he might be able to measure from farther off the ground than normal.

In these cases, it's usually best to have the GM make the call on who's flanking rather than trying to do meticulous measurements in three dimensions.