2014 M3, 2.5L (S-GT hatchback) here. My computer average MPG readings tend to be 0.5 to 2 MPG higher than my manual calculations on a consistent basis.
I always fill my tank, and I always reset the computer's average MPG reading when I fill up. Part of the discrepancy is due to the fact that when I fill up, I completely fill up; i.e., when the pump shuts off, I pull the nozzle out part way, give it about 10~15 seconds for the tank to vent & gas to settle, then I start the pump again. Repeat process till it won't take anymore, which is typically 1~2 pump restarts.
The computer bases it's calculation based on the tank's volume specification; if you fill up completely like I do, then the tank and some portion of the filler neck is full. That extra gas is not accounted for in the computer's average MPG calculation, but it is counted in the manual calculation (miles traveled/fuel used), so the manual MPG calculation will always be a bit less than the computer's reading.
FWIW, mine averages 32~33 MPG if I do nothing but commute to work, which is mostly 4 lane highway (55~65-ish, a few lights in between), with some stop & go traffic at each end.