Undervolting usually gives much better performance results than overclocking, especially when a higher voltage is needed for stability. That's because the GPU is thermally limited since it can't shed heat out of the die fast enough; a common problem now with 7nm and smaller geometry. Using liquid cooling certainly helps but it's a problem of getting the heat out of the silicon more than anything else. So the 1.200V limiter isn't really an issue unless trying to experiment with something like LN2 cooling for overclocking demonstrations and competitions.
There's also a limit to how far you can undervolt. Most 6800XT's are capable down to around 1.050V. Mine will pass benchmarks that low but I get problems such as audio distortion and failure to boot up so I run it around 1.075V. 1.125V is needed if running Folding@Home, which performs complex GPU calculations, to avoid processing errors that fail work units.
If you're eager to get into extreme overclocking the thing to look for is
More Power Tool and Red Bios Editor. They are the way to overcome several of the card limits. It also allows increasing power budget. But this is definitely the way to burn up your card...and possibly your PSU or maybe the whole rig if you aren't careful.