It really depends what you're wanting to do?, if you're only wanting a DC voltage, without any fast changes, you can have a cutoff frequency MUCH lower than 1/5th of your PWM frequency. But assuming you're using PWM for an amplifier, and you're wanting the filtered output to have a good frequency response (say 20KHz for audio), then using 100KHz for the PWM makes sense, as running it higher may require more expensive transistors, more complicated circuitry, and bigger heatsinks (higher frequency, higher losses).
But if the filter is entirely removing the PWM frequency, then increasing the PWM frequency won't have any helpful effect.