Correct, I thought it was due to the lack of TRIM. Obviously it's not, I checked my other ubuntu VMs and it pretty much matches with 16K block size and df -h. However, the largest VM has this space problem, which I don't really understand. It seems to boil down to destroying and reinstalling.
NAME PROPERTY VALUE SOURCE
rpool/data/vm-100-disk-0 volblocksize 16K default
rpool/data/vm-103-disk-0 volblocksize 16K default