The ten x flow rate is based on the filters rating not the actual flow, it is a guide line.
If we go back 10 years or so, there were several guide lines (based on tried and tested methods) that were quoted on this forum on a daily basis.
2 x T5 tubes the same length as the tank, 10 x flow rate, EI ferts, 50% weekly water change, full length spray bar, 6 hours of light building to 8 hours, Amazonia substrate...... all perfectly sensible starting points for long term success.
Still good advice today but there are always going to be exceptions and different opinions.
The flow within the tank is very important (critical even) if you are trying to evenly distribute injected C02 but the scapes layout can make a huge difference.
10 x flow through a full length spray bar is a proven way, especially in a Dutch style layout, but perhaps not necessary if you have an island scape or a carpet and branch design.
Just a guide line as part of a well tried formula to help beginners get started on the right foot.