FORM 20-F Grupo Casa Saba, S.A.B. de C.V.

Table of Contents
For Mexican income tax purposes, the following principles apply regarding residency:
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Individuals are residents of Mexico if they have established their home or habitual abode in Mexico or, if they have established their principal place of
residence outside Mexico, if their core of vital interests (centro de intereses vitales) is located in Mexico. Individuals’ core of vital interests will be deemed to
be located in Mexico if, among other things:
‣ at least 50% of the individual’s aggregate annual income derives from Mexican sources; or
‣ the individual’s principal center of professional activities is located in Mexico.
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Individuals are residents of Mexico if they are state employees, regardless of the location of the individuals’ core of vital interests.
Mexican nationals who filed a change of tax residence to a country or jurisdiction that does not have a comprehensive exchange of information agreement with
Mexico in which his/her income is subject to a preferred tax regime pursuant to the provisions of the Mexican Income Tax Law, will be considered Mexican
residents for tax purposes during the year of filing of the notice of such residence change and during the following three years.
Unless otherwise proven, a Mexican national is deemed a resident of Mexico for tax purposes.
Legal entities are residents of Mexico if they maintain their principal place of business or their place of effective management in Mexico.
If non-residents of Mexico are deemed to have a permanent establishment in Mexico for tax purposes, all income attributable to the permanent establishment
will be subject to Mexican taxes, in accordance with applicable Mexican tax law.
The applicable corporate income tax rate was 30% in 2011. The income tax rate applicable from 2010 to 2012 is 30%, 29% for 2013 and 28% for 2014 and following years.
Dividends. Under the provisions of the Mexican Income Tax Law (Ley del Impuesto Sobre la Renta), dividends paid to non-resident holders with respect to the ADSs
or Ordinary Shares will not be subject to Mexican withholding tax.
Dividends paid from distributable earnings that have not been subject to taxation at the corporate level were subject to a dividend tax at an effective rate of 42.86%
from 2010 to 2012 (40.85% for 2013 and 38.89% for 2014 and following years) at the corporate level. The corporate-level dividend tax on the distribution of earnings is not final and may
be credited against income tax payable during the fiscal year in which the dividend tax was paid and in the following two years. Dividends paid from distributable earnings, after
corporate income tax has been paid with respect to these earnings, are not subject to this corporate-level dividend tax.
Sales or Other Dispositions. Gain on the sale or other disposition of ADSs or Ordinary Shares by a non-resident holder will generally not be subject to Mexican tax.
Deposits and withdrawals of Ordinary Shares in exchange for ADSs will not give rise to Mexican tax or transfer duties.
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Gain on the sale of ADSs or Ordinary Shares by a non-resident holder will not be subject to any Mexican tax if the transaction is carried out through the
Mexican Stock Exchange or other stock exchange or securities markets approved by the Mexican Ministry of Finance and Public Credit. Such exemption shall
not apply to a person or group of persons that directly or indirectly holds 10% or more of the shares if, in a period of 24 months, such person sells 10% or more
of the shares, through one transaction or through more than one simultaneous or successive transactions. In addition, such exemption will not apply to a
person or group of persons who control the issuing company and sell their control through one or more transactions within a 24-month period.
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