Look at it like this:
The entire purpose of the "decoupling" or "bypass" caps is to make an
AC short from supply to supply, such that any abrupt current event is
returned to the chip and does not escape to bother the neighbors -
while also providing close-in "make-up" charge. It's all, all about the
current / charge loop and the internal demand.
If you decouple V+ to ground plane and V- to ground plane, but
the "event current" runs from V- to V+, your decoupling will be
half as effective for the same C overall - series C, where it counts.
In multi-rail assemblies there may be more than one need. For
example maybe you have both a super abrupt internal switching
impulse per cycle, and a ground returned driven load. In that
case you may want both a very low ESR/ESL right across the pins
(for keeping internal supply rails stiff in-the-moment) and big
"reservoir" caps to whichever rails matter to the output (could
be V+ / Gnd, could be V+ / V-, could be V- / Gnd, depending on
the function, some or all). Like 10X the driven load capacitance
if you want "only" 10% supply droop at switching transitions.
You want to minimize "loop area" (for overall inductance, likely
to dwarf internal capacitor ESL) and pretend that the supply feed
is so inductive, that any switching energy must be provided by
the capacitors (
@pin sum of internal and load).
If your chip design is fully represented then with realistic cap
component models you can do explicit design-for-power-
integrity with some confidence. But that representing, especially
board and package level parasitics can be a chore, the closer you
look.