0001047469-07-003022 Sample Contracts

FORM OF SEPARATION AND DISTRIBUTION AGREEMENT by and among TYCO INTERNATIONAL LTD., COVIDIEN LTD., and TYCO ELECTRONICS LTD. Dated as of , 2007
Separation and Distribution Agreement • April 20th, 2007 • Covidien Ltd. • Wholesale-medical, dental & hospital equipment & supplies

SEPARATION AND DISTRIBUTION AGREEMENT (this “Agreement”), dated as of , 2007, by and among Tyco International Ltd., a Bermuda corporation (“Tyco”), Covidien Ltd., a Bermuda corporation (formerly known as Tyco Healthcare Ltd.) (“Healthcare”), and Tyco Electronics Ltd., a Bermuda corporation (“Electronics”). Each of Tyco, Healthcare and Electronics is sometimes referred to herein as a “Party” and collectively, as the “Parties”.

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TAX SHARING AGREEMENT by and among TYCO INTERNATIONAL LTD., TYCO HEALTHCARE LTD., and TYCO ELECTRONICS LTD.
Tax Sharing Agreement • April 20th, 2007 • Covidien Ltd. • Wholesale-medical, dental & hospital equipment & supplies • New York

THIS TAX SHARING AGREEMENT (this “Agreement”) is made and entered into as of the day of , 2007, by and among Tyco International Ltd., a Bermuda corporation (“Tyco International”), Tyco Healthcare Ltd., a Bermuda corporation (“Tyco Healthcare”), and Tyco Electronics Ltd., a Bermuda corporation (“Tyco Electronics”). Each of Tyco International, Tyco Healthcare, and Tyco Electronics is sometimes referred to herein as a “Party” and collectively, as the “Parties”.

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