My dipstick is the same way (ej22). I always use the lower side as well. That's the side with the "L" and "F" letters, so I would assume that's the side Subaru wants you to read. It would make sense.
Unless they changed the dipstick and you have a L and F mark on both sides?
Edit: and I agree 100% with Bacon117 about checking it multiple times, each time you check.