What are some examples of holding?
Remember, radials come from a fix.  You cannot hold south of a VOR on the 360 radial in the same way that you could not hold east on a 270 radial using the VOR as the holding fix.
You could hold south on a 360 radial, but the fix would have to be somewhere away from the VOR.  For example, if you're told to hold south of the 10DME on the 360 radial, that could be done.
What that would mean is that your fix, for the purposes of the inbound course, would be the 360 radial of the VOR at the 10 DME distance.  So your racetrack pattern would be south of the point 10 miles north of the VOR (per the compass rose's north).
Examples: