Exhibit 8.1
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SIDLEY AUSTIN LLP
787 SEVENTH AVENUE
NEW YORK, NY 10019
+1 212 839 5300
+1 212 839 5599
AMERICA • ASIA PACIFIC • EUROPE
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April 29, 2026
The Brink’s Company
P.O. Box 18100
1801 Bayberry Court
Richmond, Virginia 23226-8100
Re: Registration Statement on Form S-4
Ladies and Gentlemen:
We have acted as counsel for The Brink’s Company (“Company”), a Virginia corporation, in connection with (i) the First Merger and the Second Merger,
each as defined below and described in the Agreement and Plan of Merger, dated as of February 26, 2026, by and among the Company, NCR Atleos Corporation, a Maryland corporation (“NCR Atleos”), Novus Merger Sub, Inc., a Maryland corporation and
wholly owned subsidiary of the Company (“Merger Sub I”), and Novus Merger Sub II, LLC, a Maryland limited liability company and wholly owned subsidiary of the Company (“Merger Sub II”) (as amended from time to time, the “Merger
Agreement”), and (ii) the preparation and filing of the related Registration Statement on Form S-4 (the “Registration Statement”), which includes the joint proxy statement/prospectus (the “Proxy Statement/Prospectus”), as may be
amended from time to time, filed with the Securities and Exchange Commission (the “Commission”).
Pursuant to the Merger Agreement, (i) Merger Sub I will be merged with and into NCR Atleos (the “First Merger”), with NCR Atleos surviving the First
Merger as a direct wholly owned subsidiary of the Company, and (ii) immediately following the First Merger, NCR Atleos will merge with and into Merger Sub II (the “Second Merger” and, together with the First Merger, the “Mergers”), with
Merger Sub II surviving the Second Merger as a wholly owned subsidiary of the Company.
This opinion letter is being delivered in connection with, and appears as an exhibit to, the Registration Statement. Unless otherwise indicated, each
capitalized term used but otherwise not defined herein has the meaning ascribed to it in the Merger Agreement.
April 29, 2026
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In connection with this opinion letter, we have examined the Merger Agreement, the Registration Statement (including the Proxy Statement/Prospectus),
(together with the Merger Agreement the “Transaction Documents”) and such other documents as we have deemed necessary or appropriate in order to enable us to render our opinion. In such examination, we have assumed the genuineness of all signatures,
the legal capacity of natural persons, the due authorization, execution and delivery of the Transaction Documents, the enforceability of the Transaction Documents, the authenticity of all documents submitted to us as originals, the conformity to
original documents of all documents submitted to us as duplicates or certified or conformed copies, and the authenticity of the originals of such latter documents. We have not, however, undertaken any independent investigation of any factual matter
set forth in any of the foregoing. For purposes of this opinion letter, we have assumed, with your permission, (i) that the First Merger and the Second Merger each will be consummated in the manner described in the Transaction Documents, and none of
the material terms and conditions of the Transaction Documents have been or will be waived or modified, (ii) the statements set forth in the Transaction Documents are true, complete and correct and will remain true, complete and correct at all times
up to and the Second Effective Time, (iii) there are no documents or understandings between any of the parties that would alter, or are inconsistent with, the terms or representations set forth in the Transaction Documents, and (iv) any
representations made in the Transaction Documents “to the knowledge of,” or based on the belief of the Company, Merger Sub I, Merger Sub II or NCR Atleos or similarly qualified are true, complete and correct and will remain true, complete and correct
at all times up to and including at the Second Effective Time, in each case without such qualification. We have also assumed that the parties have complied with and, if applicable, will continue to comply with, the obligations, covenants and
agreements contained in the Merger Agreement. In addition, our opinion is based solely on the documents that we have examined, the additional information that we have obtained, and the representations made by the Company and NCR Atleos referred to
above, which we have assumed will be true as of the Second Effective Time. No assurance can be given as to the effect of the opinion set forth below if any of the foregoing assumptions is or becomes inaccurate.
This opinion is based upon the Code, the Treasury Regulations promulgated thereunder, and administrative and judicial interpretations thereof, all as in
effect on the date hereof. It should be noted that the Code, Treasury Regulations, administrative and judicial interpretations and other authorities are subject to change at any time and, in some circumstances, with retroactive effect. Any change in
any of the authorities upon which our opinion is based, or any variation or difference in any facts from those set forth or assumed herein, could affect our conclusion herein. No assurance can be given that the Internal Revenue Service will agree
with this opinion or that, if the Internal Revenue Service were to take a contrary position, such position would not ultimately be sustained by the courts.
Based on and subject to the foregoing, under present United States federal income tax law, it is our opinion that the statements set forth under the
caption “Certain Material U.S. Federal Income Tax Consequences of the Mergers” in the Proxy Statement/Prospectus included in the Registration Statement, insofar as they constitute a summary of United States federal income tax considerations, are
correct in all material respects subject to the limitations and qualifications set forth therein.
We express no opinion on any issue relating to the tax consequences of the transactions contemplated by the Merger Agreement other than the opinion set
forth above.
This opinion letter is rendered only as of the date hereof and could be affected by changes in facts, circumstances, law, or other events or developments
that hereafter may occur or be brought to our attention. We assume no responsibility to advise you or any other person of any change, event, or development.
April 29, 2026
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This opinion letter is furnished to you solely for use in connection with the Registration Statement. We hereby consent to the filing of this opinion
letter as an exhibit to the Registration Statement and to the references to our firm name in the Proxy Statement/Prospectus in connection with the references to this opinion letter. In giving such consent, we do not thereby admit that we are in the
category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended, or the rules and regulations of the Commission thereunder. Except as stated in this paragraph, this opinion letter may not be relied upon by any
other person or entity for any purpose without our prior written consent.
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Very truly yours,
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/s/ Sidley Austin LLP
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