Given that the formal controlled foreign companies (CFC) reform process began more than five years ago it has been more marathon than sprint. Perhaps steeplechase is more appropriate given the apparent obstacles that have at times strewn the course. With the enactment in July of Finance Act 2012, some understandable fatigue is offset by the realisation that, from 1 January 2013, a wholly new set of rules will apply and there will be an impact for all UK companies that have foreign subsidiaries. This article gives an overview of the changes and discusses how companies may seek to respond.