Bluetooth headphones with this claim are virtualized surround, as you have strictly only Left and Right, two ears. But the head-related transfer function is taken into the mix equation. For Apple TV, this processing is done partly on the box, and partly with (compatible) headphones hardware. It will send regular stereo to other bluetooth headphones. Listen with spatial audio for AirPods and Beats - Apple Support
Apple TV doesn’t output DTS HD for any configuration.
If you connect your headphones to an audio receiver, then the audio processing doesn’t depend on Apple TV, and then different options may become available.