EXHIBIT 8.3


                    [LETTERHEAD OF APPLEBY SPURLING & KEMPE]



                                                           13 April 2001


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

Dear Sirs

REGISTRATION STATEMENT ON FORM S-4 REGISTRATION NO. 333-57850

We have acted as attorneys in Bermuda for Tyco International Ltd. ("Tyco"), in
connection with the proposed merger (the "Merger") of The CIT Group, Inc.
("CIT") with Tyco Acquisition Corp. XIX (NV) ("Tyco Acquisition"), a direct
wholly owned subsidiary of Tyco, pursuant to the Agreement and Plan of Merger
dated as of March 12, 2001 between CIT and Tyco Acquisition (the "Merger
Agreement").

In connection therewith, we have reviewed the discussion on the Bermuda tax
consequences of the Merger set forth under the caption "Bermuda Tax
Consequences" (the "Discussion") in the draft Proxy Statement/Prospectus (the
"Proxy Statement/Prospectus") which is to form part of Amendment No. 1 to the
Registration Statement on Form S-4 Registration No. 333-57850 (the "Registration
Statement") to be filed by Tyco with the United States Securities and Exchange
Commission.


In rendering our opinion, we have examined a draft of the Proxy
Statement/Prospectus e-mailed to us on 11 April 2001, the Merger Agreement and
originals or copies, certified or otherwise identified to our satisfaction, of
such corporate records of Tyco 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 Proxy
Statement/Prospectus.


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 Proxy Statement/Prospectus
and in the Merger Agreement are accurate and that when filed the Proxy
Statement/Prospectus will not differ in any material respect from the draft
which we have examined.


It is our opinion that the tax consequences of the delivery of Tyco common
shares and cash in lieu of fractional shares to CIT stockholders in exchange for
CIT common stock pursuant to the Merger 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 caption
"Bermuda Tax Consequences" in the Proxy Statement/ Prospectus.

Yours faithfully


/s/ Appleby Spurling & Kempe