Not impossible, I suppose, although such a scenario would surely be likely to result in a bang and operation of an OPD, rather than just an RCD tripping?Why cannot this be due to simple mechanical movement of previously separated cables/ terminals, when operating the switch to the off position, moving a line cable/terminal to touch and earthed part? For example, badly sheathed CPC at DP switch.
Don't forget that we're talking about a phenomenon which apparently occurs repeatedly every time the switch is moved to the off position. If L/CPC contact was occurring every time, one would surely expect something more dramatic than an RCD trip to occur on at least some occasions. I would think that there would have to be some subtle twists to what you suggest for it to be a likely explanation of what the OP is experiencing. To consistently and repeatedly get a transient L/E path during swith-off which was <~7.67 kΩ, but not very low impedance, would be pretty difficult! Having said that, any attempt to speculate as to what may be going on seems pretty hard to believe, so .....!!
Kind Regards, John