Actually, if you add the premium package to a Model 3 that only adds $5K US, so say 5000 Euro with VAT (not 15K), so 43-45K Euro using your estimate of 38-40K Euro for the base Model 3.
If you add comparable features to the PUP package to the 330i it raises the price to 56K Euros v. 43-45K for the Model 3 with PUP.
So any way you slice it, even with a 30% discount (the top end of your range), it looks like the Model 3 should be competitive on price, even in Germany, and even before taking into account incentives and cost savings from fueling with electricity instead of gasoline. And you mention Autopilot price but if someone wants Autopilot BMW doesn't have anything to offer.
Your calculation somehow is way off. See:
Base Model 3 net: 35K USD/Euro
plus 10% import duty: 3.5K Euro
plus 19% VAT: 7.3K Euro
Base Model 3 gross: 45.8K Euro
plus PUP: 5K USD/Euro (hopefully gross, not net, otherwise add another 19% VAT)
plus colour: 1K USD/Euro
Base Model 3 with colour and PUP: 51.8K Euro
minus 4K BEV subsidy:
47.8K Euro
BMW 330i base MSRP: 42.5K Euro (who buys an automatic if he doesn't have to, honestly?)
But just for fun (and because someone asked), let's take the 3
40i, with the even more expensive Steptronic Sport transmission:
BMW 340i Sport line (with 18 inch wheels) MSRP: 54.1K Euro
plus colour: 0.9K Euro
plus automatic transmission Steptronic Sport: 2.4K Euro
plus leather seats: 1.8K Euro
plus wood trim: 0.4K Euro
plus navigation package ConnectedDrive: 3.1K Euro (includes real time navigation, phone integration and wireless charging, remote services, concierge service, real time traffic information, anti theft alarm system)
plus TACC, including automatic high beam assistant: 0.8K Euro
plus speed limit info: 0.3K Euro
plus automatic parking, pdc and backup camera: 1.0K Euro
plus heated steering wheel: 0.2K Euro
plus electric glass roof: 1.1K Euro
plus power sport seats with memory: 1.1K Euro
plus heated seats front and back: 0.7K Euro
plus harman/kardon sound system 1.1K Euro
plus DAB radio: 0.3K Euro
plus TV function: 1.0K Euro
plus online entertainment incl. WiFi hotspot: 0.2K Euro
plus adaptive LED headlights incl. washer: 1.4K Euro
plus power folding, heated, auto-dimming mirrors 0.4K Euro
and you arrive at just a little under 70K Euro MSRP!
Far more than the base Model 3, BUT, now subtract the various rebates, and you arrive at
about 50K Euro, sometimes even less!
Plus, for that you get a car that is better equipped, has the 0-62 time (5.1 seconds) of the higher end Model 3, plus the quality and image of BMW, something that means a lot to many buyers, for the same money as the Model 3 base with colour and PUP (no Autopilot or FSD mind you - or even nice wheels, which you can only get when upgrading to 19 inch - at the moment, Tesla of course might add other free 18 inch wheel designs in future).
Now you can argue that the running costs of the Model 3 might be lower, but we don't really know that yet.
Tesla service is known to be very expensive, insurance premiums for the Model S are much higher than average, so those for the Model 3 could potentially be as well. And electricity is hardly free over here either. So the savings Tesla list on their website might be true for the US, for Germany they are highly exaggerated.
Again, I am sure I will get my Model 3 anyway (unless the proposed BMW 3-series BEV turns out to be a better offer), I just wanted to show you why your calculation (and following conclusion) is way off.