uncertain tax positions the following is a reconciliation of the company's beginning and ending amount of uncertain tax positions ( in millions ) : .

2015
2014
Balance at January 1
$191
$164
Additions based on tax positions related to the current year
31
31
Additions for tax positions of prior years
53
10
Reductions for tax positions of prior years
(18)
(6)
Settlements
(32)
—
Business combinations
—
5
Lapse of statute of limitations
(5)
(11)
Foreign currency translation
(2)
(2)
Balance at December 31
$218
$191

the company's liability for uncertain tax positions as of december 31 , 2015 , 2014 , and 2013 , includes $ 180 million , $ 154 million , and $ 141 million , respectively , related to amounts that would impact the effective tax rate if recognized .
it is possible that the amount of unrecognized tax benefits may change in the next twelve months ; however , we do not expect the change to have a significant impact on our consolidated statements of income or consolidated balance sheets .
these changes may be the result of settlements of ongoing audits .
at this time , an estimate of the range of the reasonably possible outcomes within the twelve months cannot be made .
the company recognizes interest and penalties related to uncertain tax positions in its provision for income taxes .
the company accrued potential interest and penalties of $ 2 million , $ 4 million , and $ 2 million in 2015 , 2014 , and 2013 , respectively .
the company recorded a liability for interest and penalties of $ 33 million , $ 31 million , and $ 27 million as of december 31 , 2015 , 2014 , and 2013 , respectively .
the company and its subsidiaries file income tax returns in their respective jurisdictions .
the company has substantially concluded all u.s .
federal income tax matters for years through 2007 .
material u.s .
state and local income tax jurisdiction examinations have been concluded for years through 2005 .
the company has concluded income tax examinations in its primary non-u.s .
jurisdictions through 2005 .
9 .
shareholders' equity distributable reserves as a u.k .
incorporated company , the company is required under u.k .
law to have available "distributable reserves" to make share repurchases or pay dividends to shareholders .
distributable reserves may be created through the earnings of the u.k .
parent company and , amongst other methods , through a reduction in share capital approved by the english companies court .
distributable reserves are not linked to a u.s .
gaap reported amount ( e.g. , retained earnings ) .
as of december 31 , 2015 and 2014 , the company had distributable reserves in excess of $ 2.1 billion and $ 4.0 billion , respectively .
ordinary shares in april 2012 , the company's board of directors authorized a share repurchase program under which up to $ 5.0 billion of class a ordinary shares may be repurchased ( "2012 share repurchase program" ) .
in november 2014 , the company's board of directors authorized a new $ 5.0 billion share repurchase program in addition to the existing program ( "2014 share repurchase program" and , together , the "repurchase programs" ) .
under each program , shares may be repurchased through the open market or in privately negotiated transactions , based on prevailing market conditions , funded from available capital .
during 2015 , the company repurchased 16.0 million shares at an average price per share of $ 97.04 for a total cost of $ 1.6 billion under the repurchase programs .
during 2014 , the company repurchased 25.8 million shares at an average price per share of $ 87.18 for a total cost of $ 2.3 billion under the 2012 share repurchase plan .
in august 2015 , the $ 5 billion of class a ordinary shares authorized under the 2012 share repurchase program was exhausted .
at december 31 , 2015 , the remaining authorized amount for share repurchase under the 2014 share repurchase program is $ 4.1 billion .
under the repurchase programs , the company repurchased a total of 78.1 million shares for an aggregate cost of $ 5.9 billion. .

Question: Analyse this data from a financial earnings document. what is the difference between the liability for uncertain tax positions as of december 31 , 2015 and the balance of the uncertain tax positions at december 31 , 2015 , ( in millions )
Choices:
38.0
38
213
165
398
Correct choice index: 0