Abstract: This study discusses about the difference of linguistic strategies used by the Malays and Spanish in implementing the speech act of refusal. A number of 40 Malay graduate students and 40 Spanish graduate students participated in this study. Data was collected by using DCT method or discourse completion test introduced by Blum-Kulka. The data was analysed based on the refusal model Beebe. Beebe divided refusal act into three categories, namely, direct refusals, indirect refusal and adjuncts to refusals. Overall, the result showed that the Spanish use more strategies than the Malays but they are more direct in refusing as compared to the Malays. It was found that these two nations, Malays and Spanish, use the same strategies while making refusal but differ in frequency and trends. The interesting part is about the use of motives “husband” and “going back to hometown” in Malay refusal data exist but none in Spanish data.