It should not matter whether the sub report is a referenced file or is set inline in the main report. The behavior should be the same. One way of finding the problem is to set background color and borders of the main and sub-report sections in order to see how they are laid out. If this suggestion does not help, please open a support ticket and send us the report definitions which exhibit the issue so that we can review them locally.
All the best,
the Telerik team
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