Exhibit 8.3


                        [LETTERHEAD OF BIRD & BIRD]



                                  June 18, 2003



Zimmer Holdings, Inc.
345 East Main Street
Warsaw, Indiana 46580


Dear Ladies and Gentlemen:

            We are acting as special U.K. tax counsel to Zimmer Holdings, Inc.
(the "Company") in connection with the Company's offer to exchange common stock
of the Company and cash for all of the issued and outstanding registered shares
and American depositary shares of Centerpulse AG, a corporation organized under
the laws of Switzerland. You have asked us to provide this opinion in connection
with the Registration Statement on Form S-4 filed by the Company with the
Securities and Exchange Commission (the "SEC") pursuant to the Securities Act of
1933, as amended (the "Act"), in connection with the exchange offer (the
"Registration Statement").


            We hereby confirm to you that the discussion in the Registration
Statement under the caption "Our Offer -- Taxation -- Material U.K. Tax
Consequences," to the extent it states matters of law or legal conclusions and
subject to the qualifications and limitations stated therein, is our opinion. In
giving our opinion, we have relied upon the accuracy and completeness of the
other statements contained in the Registration Statement.



            We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to us under the caption "OUR OFFER
- -- Taxation." In giving such consent, we do not admit that we are in the
category of persons whose consent is required under Section 7 of the Act or the
rules and regulations of the SEC thereunder.



                                    Very truly yours,

                                    Bird & Bird