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

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, 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 ( 18 ), -6 ( 6 )
settlements, -32 ( 32 ), 2014
business combinations, 2014, 5
lapse of statute of limitations, -5 ( 5 ), -11 ( 11 )
foreign currency translation, -2 ( 2 ), -2 ( 2 )
balance at december 31, $ 218, $ 191
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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: 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 )
Program: subtract(218, 180)
Answer: 38.0