From memory, generally, Vne is 90% of demonstrated design dive speed. Flutter speed to be proven to be above demonstrated Vd by a further margin - so, with Vd specified in EAS then it has to be shown at high altitude to get the highest TAS. Flutter may not be critical, could be tailplane balancing/manoeuvre or gust loads or wing gust loads etc. Flutter can also appear well below Vd yet have no flutter approaching Vne.
Best not to assume what is limiting.
I'd trust the numbers and the inherent margins in the flight manual of an airplane certified to FAR 23. One or two others I have seen to be wishful thinking wrt demonstrated margins.