Well, It's all about signal return. If the power plane in question is the one powering the driver and also a receiver, then there is no difference.
Simple example. If we have an IC powered by 3V3, we might as well call it's VDD "ground" and it's GND as "-3V3".
In practice we preffer GND to be our return path, because usually it's common for everything which might be on the board and outside the board and thus is a universal return path. What you don't want is return path having to make extra jumps or taking extra paths.