It's more than that. Tesla doesn't offer wholesale on Teslas because Tesla doesn't wholesale them. They beat CarMax offers for the 2 BMWs I traded in on the Model X and 3, because they just play middleman in those deals. Since they don't wholesale their own vehicles, you're directly competing with their manufacturing costs. The second thing to consider is that software options have absolutely no value to them. The trade-in for an AP/FSD vehicle and one without AP is identical as far as Tesla is concerned, because they can add it for no cost to themselves.
The problem is even worse than in the traditional dealer model, because the profit is split between manufacturer and dealer. A BMW dealer might be willing to pay more than wholesale for a high demand model or particularly clean/low mileage example because they can still turn a profit. They don't make the cars themselves, so they have a limited allotment, especially for really high demand models.
Personally, since Tesla has stopped reconditioning pre-owned vehicles, I think they should get out of the used market entirely and partner with a national used car chain like CarMax, Carvana, Vroom, etc. By keeping Teslas out of the wholesale market, they're doing a large disservice to their owners and hurting brand loyalty. Certify somebody like CarMax to recondition cars, let the market drive wholesale trade values and stop low-balling their loyal owners.