I had a colleague of mine whose BMW was broken into at night. He woke up to police in front of his house (called by BMW's own alert system), there's an atmospheric pressure sensor inside the car and everything.
No sign of the thieves, so he booked an appointment to have the window fixed and didn't think much of it. But then he realized the side panel (in the door column? the column between the front and rear doors) was tweaked over a bit.
The thieves had gone in and cut the cable tree going to the roof of the car, which contains amongst other things the antenna and connection to BMW's alert service. Their plan was to come in the one night, disappear, hope the victim didn't notice that (and the garage doesn't check for it), and come in to steal it for real the next day, or maybe even the same night after the police has gone again.
For Tesla, if they really want they could pry open the frunk and remove the 12V power from the low-voltage battery, then winch the car onto a flatbed. That would disable the GPS tracking and allow access to make money parting out the car. Although not the motors, which are locked to the VCSEC and the owner's configured keys, and bypassing that is still an open problem AFAIK.