EXHIBIT 8.3

                                                    MLJ/af/73287.93
                                                    Direct e-mail: mjones@ask.bm

M L JONES
PARTNER

                                                                18 October 2000

Tyco International Ltd.
The Zurich Centre, Second Floor
90 Pitts Bay Road
Pembroke HM 08

Dear Sirs

TYCO INTERNATIONAL LTD. (THE "COMPANY") - REGISTRATION STATEMENT ON FORM S-4
REGISTRATION NO 333 - [   ]
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We have acted as attorneys in Bermuda for the Company in connection with the
Registration Statement on Form S-4 (File No. 333-[ ]) (the "Registration
Statement") filed by the Company with the United States Securities and
Exchange Commission under the Securities Act of 1933 (as amended). Pursuant
to the Registration Statement Tyco Acquisition Corp. X ("Tyco Acquisition"),
a wholly owned subsidiary of the Company, has offered to exchange (the
"Exchange Offer") a fraction of the Company's common shares (the "Common
Shares"), for each outstanding share in InnerDyne, Inc. ("InnerDyne") and
following consummation of the Exchange Offer to issue common shares in or
pursuant to certain rights in connection with the proposed merger of
InnerDyne with VLMS Inc. ("Merger Sub") an indirect wholly owned subsidiary
of the Company pursuant to the Agreement and Plan of Merger dated as of
October 3, 2000 among Tyco Acquisition, Merger Sub and InnerDyne (the "Merger
Agreement").

In connection therewith, we have reviewed the discussion on the Bermuda tax
consequences of the Exchange Offer set forth under the caption "Bermuda Tax
Consequences" (the "Discussion") in the Registration Statement.

In rendering our opinion, we have examined a draft of the Registration Statement
emailed to us on 13 October 2000 and dated 18 October 2000, the Merger
Agreement and originals or copies, certified or otherwise identified to our
satisfaction, of such corporate records of the Company maintained at its
Registered Office in Bermuda as we have deemed necessary or appropriate in
connection with this opinion. Terms not otherwise defined herein have the
meanings assigned to them in the Registration Statement.

In stating our opinion we have assumed, the authenticity, accuracy and
completeness of all documents submitted to us as originals, the conformity to
authentic original documents of all documents submitted to us as certified,
conformed, notarised or photostatic copies, the genuineness of all signatures on
such documents, that the factual statements in the Registration Statement and in
the Merger Agreement are accurate and



Tyco International Ltd.               -2-                      18 October 2000

that when filed the Registration Statement will not differ in any material
respect from the draft which we have examined.

It is our opinion that the Bermuda tax consequences of the delivery of the
Common Shares to the InnerDyne shareholders in exchange for InnerDyne common
stock pursuant to the Merger Agreement are as set forth in the Discussion. Our
opinion is limited to such matters as of its date, is to be governed by and
construed in accordance with the laws of Bermuda and we express no opinion as to
the laws of any other territory or jurisdiction.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to our firm under the captions
"Bermuda Tax Consequences" in the Registration Statement.

Yours faithfully,


/s/ Appleby Spurling & Kempe