Yes. If you have Btrfs in dom0 then you already have those features at the VM level at least. And I would recommend against putting Btrfs on top of Btrfs, as its more CPU intensive.
For those who have the default LVM in dom0, Btrfs in appVMs is a better prospect. But since LVM also has snapshots, to me the only two overriding reasons to use Btrfs this way is for compression (Btrfs has Zstandard now!) of things like databases and email archives; and also for its integrity checking.