I say technically as by definition they are but in the way they are treated I'd say they're not.
I'd say the difference between Wales and England as a whole is no different in spirit to the difference between Yorkshire and Essex or Cornwall and East Anglia.
Wales' counties have the same powers as any other county in the UK. However, Wales as a country also has devolved powers in it's own right.
As anywhere else, different areas have different levels of cultural self-identity - in that sense I can understand a comparison between Wales (country) and Cornwall (county) although not to Yorkshire, etc.
I say technically as by definition they are but in the way they are treated I'd say they're not.
I'd say the difference between Wales and England as a whole is no different in spirit to the difference between Yorkshire and Essex or Cornwall and East Anglia.