I worked as a mastering engineer for a couple years back in the aughts, and I can confirm that to really max things out requires production techniques.
For example, analog tape naturally saturates high frequency sounds before low frequency sounds, which brings down the peak level of a close mic'd drum. Peak limiting a recording which already has analog-saturated drums produces fewer audible artifacts.
In the abstract, at mastering-time you can achieve any absolute level without hard-clipping by smushing down the peaks with peak limiting and multi-band compression, then dialing things back up with makeup gain. But when compared against the original recording in a level matched test, at some point the processed result becomes unacceptably degraded.