Strictly, you need to find the point on the tooth whose tangent is radial – i.e. the transition between the internal and external cycloid.
Without details of the cutter this is not easy to determine and is affected by exactly how the cutter was set up.
It matters because of the geometry meaning the gear works ideally when the two meshing gears have coincident pitch circles or lantern pinions have the centres of their pins on the PCD.
The ubiquity of tools for setting the mesh of clock gears (depthing tools) and their absence in the world of involute gears is testament to the challenge of meshing clock gears accurately and the contrasting tolerance of involute gears of centre distance errors.
I would guess your method might slightly underestimate the PCD due to clearance (as explained by another poster) but should get you close enough to use a depthing tool to place the pivot correctly.
Neil