Read the following texts and table with financial data from an S&P 500 earnings report carefully.Based on the question-answer history (if provided), answer the last question. The answer may require mathematical calculation based on the data provided.


the aggregate changes in the balance of gross unrecognized tax benefits , which excludes interest and penalties , for 2012 , 2011 , and 2010 , is as follows ( in millions ) : . <table class='wikitable'><tr><td>1</td><td>-</td><td>2012</td><td>2011</td><td>2010</td></tr><tr><td>2</td><td>beginning balance</td><td>$ 1375</td><td>$ 943</td><td>$ 971</td></tr><tr><td>3</td><td>increases related to tax positions taken during a prior year</td><td>340</td><td>49</td><td>61</td></tr><tr><td>4</td><td>decreases related to tax positions taken during a prior year</td><td>-107 ( 107 )</td><td>-39 ( 39 )</td><td>-224 ( 224 )</td></tr><tr><td>5</td><td>increases related to tax positions taken during the current year</td><td>467</td><td>425</td><td>240</td></tr><tr><td>6</td><td>decreases related to settlements with taxing authorities</td><td>-3 ( 3 )</td><td>0</td><td>-102 ( 102 )</td></tr><tr><td>7</td><td>decreases related to expiration of statute of limitations</td><td>-10 ( 10 )</td><td>-3 ( 3 )</td><td>-3 ( 3 )</td></tr><tr><td>8</td><td>ending balance</td><td>$ 2062</td><td>$ 1375</td><td>$ 943</td></tr></table> the company includes interest and penalties related to unrecognized tax benefits within the provision for income taxes . as of september 29 , 2012 and september 24 , 2011 , the total amount of gross interest and penalties accrued was $ 401 million and $ 261 million , respectively , which is classified as non-current liabilities in the consolidated balance sheets . in connection with tax matters , the company recognized interest expense in 2012 and 2011 of $ 140 million and $ 14 million , respectively , and in 2010 the company recognized an interest benefit of $ 43 million . the company is subject to taxation and files income tax returns in the u.s . federal jurisdiction and in many state and foreign jurisdictions . for u.s . federal income tax purposes , all years prior to 2004 are closed . the internal revenue service ( the 201cirs 201d ) has completed its field audit of the company 2019s federal income tax returns for the years 2004 through 2006 and proposed certain adjustments . the company has contested certain of these adjustments through the irs appeals office . the irs is currently examining the years 2007 through 2009 . in addition , the company is also subject to audits by state , local and foreign tax authorities . in major states and major foreign jurisdictions , the years subsequent to 1989 and 2002 , respectively , generally remain open and could be subject to examination by the taxing authorities . management believes that an adequate provision has been made for any adjustments that may result from tax examinations . however , the outcome of tax audits cannot be predicted with certainty . if any issues addressed in the company 2019s tax audits are resolved in a manner not consistent with management 2019s expectations , the company could be required to adjust its provision for income tax in the period such resolution occurs . although timing of the resolution and/or closure of audits is not certain , the company believes it is reasonably possible that tax audit resolutions could reduce its unrecognized tax benefits by between $ 120 million and $ 170 million in the next 12 months . note 6 2013 shareholders 2019 equity and share-based compensation preferred stock the company has five million shares of authorized preferred stock , none of which is issued or outstanding . under the terms of the company 2019s restated articles of incorporation , the board of directors is authorized to determine or alter the rights , preferences , privileges and restrictions of the company 2019s authorized but unissued shares of preferred stock . dividend and stock repurchase program in 2012 , the board of directors of the company approved a dividend policy pursuant to which it plans to make , subject to subsequent declaration , quarterly dividends of $ 2.65 per share . on july 24 , 2012 , the board of directors declared a dividend of $ 2.65 per share to shareholders of record as of the close of business on august 13 , 2012 . the company paid $ 2.5 billion in conjunction with this dividend on august 16 , 2012 . no dividends were declared in the first three quarters of 2012 or in 2011 and 2010. .
Question: what is the net change in gross unrecognized tax benefits from 2010 to 2011?
Answer: 432.0
Question: what is the balance of gross unrecognized tax benefits in 2010?
Answer: 943.0
Question: what percentage change does this represent?

0.45811