FORM OF SEPARATION AND DISTRIBUTION AGREEMENT by and among TYCO INTERNATIONAL LTD., COVIDIEN LTD., and TYCO ELECTRONICS LTD. Dated as of , 2007Separation and Distribution Agreement • June 5th, 2007 • Covidien Ltd. • Surgical & medical instruments & apparatus • New York
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”.
TAX SHARING AGREEMENT by and among TYCO INTERNATIONAL LTD., COVIDIEN LTD., and TYCO ELECTRONICS LTD. Dated as of , 2007Tax Sharing Agreement • June 5th, 2007 • Covidien Ltd. • Surgical & medical instruments & apparatus • 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”), Covidien Ltd., a Bermuda corporation (“Healthcare”), and 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”.
