It's common for cars with AWD systems where the rear drivetrain can't be disconnected by a clutch to require flatbed towing, less because the car can't physically be moved with the power off and more because spinning the wheels at a sustained high speed will cause damage to the drivetrain and potentially the engine. E.g. my moldy old Subaru requires flatbed towing, because spinning the rear wheels while the fronts are immobile will destroy the limited-slip center diff, but it's totally possible to push it along with all four wheels on the ground.

I think AWD Teslas have an independent motor and drivetrain for the rear wheels. Naively, one would expect that if you unload the rear axle motor/generator you could just tow the car with little resistance and no damage, but in practice the picture is probably more complicated. I would love to hear from an expert.