We have simulated ungrounded horizontal loop transient responses of a two-layer earth consisting of a magnetically viscous layer above (model 1) or below (model 2) a nonmagnetic layer. The transient responses of a two-layer magnetically viscous earth can be computed using the superposition principle because magnetic relaxation and eddy current responses are independent at electrical conductivities typical of the real subsurface. The transients are presented and analyzed in the form of Y = f(h1) functions, where h1 is the upper layer thickness and Y is the response (at some fixed time) of a two-layer ground normalized to that of a uniform ground with its magnetic viscosity as in the upper (model 1) or lower (model 2) layer. In model 1, the Y function increases as magnetic viscosity grows in the upper layer while the latter is thinner than the loop size, but the magnetic relaxation responses of a thicker upper layer are almost identical to that of a uniform magnetically viscous ground. In model 2, the Y responses are likewise almost identical to that of a uniform magnetically viscous ground (h1 = 0) as far as the thickness of the upper layer remains small, but they decrease, first slowly and then ever more rapidly, after the layer becomes 15–20% thicker than the transmitter size. The effective sounditng depth in a magnetically viscous ground being controlled by the size of the transmitter, it is reasonable to use geometrical sounding to resolve the vertical distribution of magnetic viscosity.