Why it matters in practice
The two arrangements have different TLS endpoints and trust requirements. Encrypting the client-to-proxy hop does not automatically let the proxy read an HTTPS destination request, and it does not mean that the destination connection has been inspected. Clients need the right proxy endpoint and certificate validation for the selected topology.
Example
A client first opens TLS to its HTTPS proxy, then asks it to establish a CONNECT tunnel to api.example.com.
Educational note
This definition is general information, not legal advice. It may omit facts that matter to a specific situation and does not establish or guarantee compliance.