No, I strongly suspect that the actual L-N loop would be much less than Zs in a TT as you say.
But really my point is that we shouldn't be guessing - we should be checking.
On a TNx usually the Zs is higher than the L-N loop purely because the cpc portion is 2.5/1.5× or 4/2.5x the neutral resistance, which isn't a great difference; however in TT they are vastly different, - could be orders of magnitude.
So actually using 1667 or 200 is totally irrelevant, you wouldn't be cross checking this anyway, you would be using the rcd actual tests to prove it's OK.
As for the osg saying it should meet the same disconnection times, I am not sure it does, but I am more familiar with the regs, than the osg as I don’t need it that often, so happy to be wrong.
But that is sort of what I am saying, there is no MUST disconnect, but it should disconnect within a reasonable time frame. (if that's within the same times, great)