The purpose of the present study is to investigate pragmatic transfer in refusals by native speakers of Mandarin speaking English, and to what extent transfer is influenced by the learners' level of L2 proficiency. The elicitation instrument used for data collection was the discourse completion questionnaire developed by Beebe et al. [Beebe, L., Takahashi, T., Uliss-Weltz, R., 1990. "Pragmatic transfer in ESL refusals." In: Scarcella, R. et al. (Eds.), "Developing Communicative Competence in a Second Language." Newbury House, New York, pp. 55-73] Participants in this study were composed of four groups: 35 American college students (AE), 41 English-major seniors (SE), 40 English-major freshmen (FE), and 40 Chinese-major sophomores (CC). The refusal responses were analyzed in terms of (1) the frequency of semantic formulas, and (2) the content of semantic formulas. It was found that while all groups employed a similar range of semantic formulas in responding to the refusals elicited by different initiating acts, they differed in the frequency and content of the semantic formulas. (Contains 14 tables.)