I suppose that would depend on what type of OS was being used to export the NFS volume. If it's a POSIX system, then it's using the same sort of OS-level system library call at the server, and given that old and new paths are on the same disk volume (we're just moving an inode out of one directory into another) it will be atomic, so the net result will be the same: no two separate processes will be able to rename the same file.
That said, I just found a report that some (slightly) older versions of MacOSX were not actually using an atomic implementation of rename - but it seems that's been fixed.
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