FORM OF SEPARATION AND DISTRIBUTION AGREEMENT by and between TWENTY-FIRST CENTURY FOX, INC. and FOX CORPORATION Dated as of [•], 2019Separation and Distribution Agreement • January 23rd, 2019 • Fox Corp • Television broadcasting stations • Delaware
This SEPARATION AND DISTRIBUTION AGREEMENT (this “Agreement”), dated as of [•], 2019, by and between Twenty-First Century Fox, Inc., a Delaware corporation (“Remainco”), and Fox Corporation, a Delaware corporation and a wholly owned Subsidiary of Remainco (formerly named New Fox, Inc. and at times referred to as such in documentation relating to the Separation and Distribution (each as defined below)) (“FOX” and together with Remainco, each a “Party” and collectively the “Parties”). Capitalized terms used in this Agreement shall have the respective meanings ascribed thereto in Article I of this Agreement.
FORM OF TAX MATTERS AGREEMENT Between TWENTY-FIRST CENTURY FOX, INC., FOX CORPORATION, and THE WALT DISNEY COMPANY Dated as of [•]Tax Matters Agreement • January 23rd, 2019 • Fox Corp • Television broadcasting stations • Delaware
This TAX MATTERS AGREEMENT (this “Agreement”), dated as of [•], by and between TWENTY-FIRST CENTURY FOX, INC., a Delaware corporation (“Remainco”), FOX CORPORATION, a Delaware corporation and a wholly owned subsidiary of Remainco (formerly named New Fox, Inc.) (“FOX”), and THE WALT DISNEY COMPANY, a Delaware corporation (“Disney”).
