As the Director of Finance of Apfel, Michael McMonaghan has found out that Apfel might face the transfer pricing regulations risk for tax avoidance. He realized that both subsidiaries in Ireland had been granted undue tax benefits by the Irish government after recalculating the retrospective tax assessments. This had been in contrast with the European Commission state aid rules. He faces an ethical dilemma about the newfound information. There is a discussion between Michael and Rebecca Quin, the Director of Operations of Apfel, about whether there is a need for the changes of operation structure in the two subsidiaries. There is an argument between Michael and Scott Trenton, the representative from Apfel in the United States, about the ethical issues of their current tax practice. Corporate governance practices in Apfel also contribute towards aggressive tax planning. Michael will have to take some actions as the Director of Finance to solve the ethical dilemmas arising from the aggressive tax planning that is legal but unethical.

Should Apfel change its operations and/ or organizational structure? How can it avoid such transfer pricing issues from arising in the near future?