As I point out here: https://forums.plex.tv/discussion/comment/1540754#Comment_1540754 it is possible to reconfigure Plex so that it uses Direct Play when playing HEVC content on the Apple TV and on iOS devices. However, this currently requires modifying files that I don’t think are really intended to be edited by users. Is official HEVC support coming in a future update? I have around 13,000 HEVC files and playback works much better when Plex isn’t trying to transcode (especially fast forward and rewind).
Early 2021 clean-up: implemented (some specific stream configurations might still require a transcode)