It all depends how far and on what side.
When pulling the skid, I pull the sled over on its side and rest the handlebar on a 5 gallon bucket. I make it a point of tilting it over on it's right side, never spilled any oil. Having rolled my phazer entirely too many times, my airbox been 'oiled' several times.
If you're ever buying a phazer, make a point of doing the white glove test to the airbox - see if it's spent any time upside down.