I ran into this issue today, May 31, 2022. Previously, my app used AdMob to show ads, so I had answered all the tracking questions and implemented the ATT permission request. But then I decided to remove AdMob. The new update had absolutely no tracking, but as others have mentioned, I could not update the app's privacy information to indicate it did not track. My update was rejected. However, I replied to the App Review team in App Store Connect and explained the situation. I got impatient after three hours with no reply to my message from App Review, so I filed an appeal explaining the same as in my previous message. I immediately got a reply from App Review saying that my app would be approved shortly. It was approved minutes later and I released it. I was then able to update the app's privacy information to say "No, we do not collect data from this app". I don't know if it was my initial reply to App Review or the appeal I made three hours later that got it approved. Either way, I think I would say that right now the process for this situation is: Submit your update removing all tracking, Get rejected, Appeal the rejection explaining your app no longer tracks, Then update the privacy information after getting approved and releasing.

I have the same issue with Xcode 15.2. I am using the symlink workaround for now.