The EASA wording is on where the Operator is based.
The location (or usual location) of the aircraft might one day feature in somebody's interpretation of where the Operator is based, but currently it appears nothing to do with it.
One definition of an Operator is whoever controls where the aircraft flies. This leads to various pretty obvious solutions/workarounds for many higher-end ops. It is not helpful for the typical single private owner-pilot (like myself) but if e.g. you imagine an aircraft rental outfit which is based on the IOM which runs a booking website, and owns the aircraft, and can refuse any given booking attempt, then presumably that outfit is the Operator.
And if I can think of that, I am sure that aviation lawyers are well on the case already.
It's just the small people that are getting shafted by EASA, not the bigger stuff which is emotionally the biggest red rag to the anti foreign reg bulls.