For DC, a ground reference is required. What is not required for a high side dimmer is that the ground from the load goes through the dimmer. Most of the readily available cheap PWM dimmers work by switching the negative side of the circuit rather than the positive side, so the negative connection from the fixture must go through the dimmer module. A high side dimmer modulates the positive lead.
For traditional AC dimmers, they will work in either leg of the circuit without needing any reference to the other as they're effectively just bipolar voltage sensitive switches (a triac triggered by a diac or something similar). That, of course, is uninteresting for 12V RV lighting.