This has never been mentioned before. No one has ever reported a need to compensate.
The logical guess, from experience, is that this is NOT built into the game.
You can easily test this by creating a mission with a staionary target with a know keel depth and fire a torp set just for below that depth and watch it on the external view window. Set the pistol on impact so it won't go off as it slides right under the bottom edge of the ship's hull.
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