I don't know what the limit is, but there is definitely degradation in performance after a few thousand files.
On NTFS systems, this is most likely app-related such as Explorerer where they have to deal with slogging through all the extra files, as noted by another poster. An App opening a specific file will see almost no degradation because the NTFS uses a tree structure to maintain fast access to a file by name.
There is a separate issue where NTFS doesn't recover unused directory space after deleting many files. This only becomes an issue with files numbering in the millions....
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