Communication breakdowns can occur during cross-cultural communication due to different perceptions and interpretations of appropriateness and politeness. This study investigates similarities and differences between refusals in American English and Thai and incidences of pragmatic transfer by Thai EFL learners when making refusals. The participants of the study include Thai and American native speakers and EFL learners. All of them are graduate students. The data were collected by means of a discourse completion test (DCT) which was designed on the basis of interviews carried out with a view to possible situations for refusals. EFL data for refusals were compared with similar data elicited from native speakers of American English and Thai. Results indicate that overall all three groups share most of the refusal strategies and that pragmatic transfer exists in the choice and content of refusal strategies. Awareness of a person of a higher status and the characteristics of being modest in L1 culture motivate pragmatic transfer. Language proficiency is also an important factor in pragmatic transfer. In making refusals, EFL learners with lower English proficiency translate from L1 to L2 because of their lack of L2 pragmatic knowledge. (Contains 4 tables.)