Exhibit 8.1

MATERIAL SUBSIDIARIES

Our operations are conducted principally by Ambev, and, in the case of our HILA-Ex, Latin America South and Canadian operations, by direct and indirect subsidiaries of Ambev.  The following is a list of the significant companies that Ambev controlled, either directly or indirectly, as of December 31, 2013:

·The Company, directly and indirectly, owns 100% of the economic and voting interests in Ambev Luxembourg (incorporated in Luxemburg) which owns 100% of Labatt Brewing Co. Ltd. (incorporated in Canada).  These entities explore the production of beer in Canada.

·The Company owns 100% of the economic and voting interests in Linthal ROU S.A., which, through its subsidiaries, produces and sells beer and soft drinks in Uruguay and other South American countries.

·The Company, directly and indirectly, owns 100% of the economic and voting interests in Arosuco Aromas e Sucos Ltda. (incorporated in Brazil), which produces concentrates for our soft drinks and crowns. 

·The Company, directly and indirectly, owns 100% of the economic and voting interests in Eagle Distribuidora de Bebidas S.A. (incorporated in Brazil). 

·The Company, directly and indirectly, owns 100% of the economic and voting interests in Jalua Spain S.L. (incorporated in Spain). 

·The Company, directly and indirectly, owns 100% of the economic and voting interests in Monthiers S.A. (incorporated in Uruguay). 

·The Company, directly and indirectly, owns 100% of the economic and voting interests in CRBS S.A (incorporated in Brazil), which produces and sells beer and soft drinks in Brazil.