I think both ways are OK. More important is to understand, which is more noiseless: Vdd or Vss. You should always try to minimise noise, which can couple to XTAL.
If decoupling to Vss (=GND) is sharing common impedance with some other high current source, then it might be wiser to connect XTAL caps to Vdd. This requires that PDN (power delivery network) has a low impedance also at XTAL frequencies and above. Might require some capacitor optomizations...
Normally GND potential has lower noise level than power supply, but not always. Basic EMC!
BR,
-Gusse-
Bookmarks