So you're suggesting to create multiple fake apple accounts and use them to build apps for personal use? I think that Apple would find out and ban those accounts, because surely they made that restriction to restrict exactly this behaviour (abusing developer account to by-pass AppStore). Does someone use that approach?

Fake accounts makes it sound like some “thing”. Just using a couple of different accounts for most any public-ish big service is pretty par for the course.

Not sure what “does someone use that approach” mean. I can just say Apple for sure does not do any sort of banning of any kind if you use a handful of accounts with one device.

There’s probably people in the sideloading and jailbreak community who have a dozen accounts linked to one device. I’ve never thought of it as anything more than just doing some simple relatively innocent thing to get around the 3 limit. No problems to the at this point probably dozen accounts I have.