Considering that's what MicroChip say, I'm with you
However, if you use BRG16 = 1, then you can get 0.01% and 0.03% on a limited number of low speed baud rates - 300, 1200 and 2400. Or with BRGH = 1 and BRG16 =1, even 0% on some, and 0.03% on 9600.
Not that all this matters of course, the whole point of asynchronous connection is that it doesn't need to be perfectly accurate, as it re-syncs every ten bits. The MIcroChip table offers values as 'poor' as 3.55% out.