Your calcs are spot on.
I noticed this as well with my GTD, typically it's only 0.5-1.5mpg optimistic from the brim to brim, and taking into account that even brim to brim has a deviation of inaccuracy (forecourt delivery accuracy, temperature, filling to exact same point each time etc), then it's much more accurate than my older Scirocco which was about 17% inaccurate (before I tweaked it in VCDS).