When mixing drums I’ve always tried panned toms to match where they locate in the overhead mics.
It’s worked for me, but it’s never been something I’ve thought too much about or experimented with.
While watching Steve Albini work during my week at Mix With The Masters, I noticed he had hard panned the rack and floor toms, which surprised me. I’d always thought hard panning toms that would sound like some ridiculously exaggerated 80s drum swirly thing, but it still sounded quite natural while defining the tom hits a bit more.
I’ve tried it on a couple of mixes since coming back, and have been really satisfied with the results.
Now, maybe it’s because my drum micing scheme was already a bit similar to how Steve mics drums, but give it a go, it might work for you too.