Have never included a surcharge. Personally I just consider it another business expense.
It seems Paypal has changed the way they handle the fees in the past year. There used to be an option where the payee could choose to eat the surcharge, and sometimes clients would pay it which was always cool. But that option doesn’t seem to exist anymore, which is kind of strange. Because sometimes you want to make sure the “seller” gets the full amount (like when I send my landlord money).