Sounded good at the time. 
iZotope has a Dithering with Ozone PDF, that, contrary to what the title suggests, is 85% about dithering in general.
In relation to my query, on page 25, they state:
Don’t Loudness Maximize to 0 dB and then try to add dither, or even filter DC offset. You could go
over.
My question is answered with a ‘Yes’, it can tip 0FS to clipping.