In what countries can you *not* disclaim copyright?
<p>I'm interested in some of the legal issues around software licensing, but my question could apply to other copyrightable works too.
Most free and open source software is copyrighted but distributed under some license that grants others the right to use it.
Other authors instead opt to disclaim copyright entirely and dedicate their work to the public domain.
There is some debate about whether this is a good thing to do or not, see for example this <a href="https://opensource.org/node/878" rel="noreferrer">article</a> from the open source initiative.
In that article and others, I've seen a statement made that "Disclaiming copyright is only possible in some countries."</p>

<p><strong>In what countries can you disclaim copyright? In what countries can you not disclaim copyright?</strong> For example, <a href="https://gettingthedealthrough.com/area/6/jurisdiction/11/copyright-germany/" rel="noreferrer">this page</a> seems to say that, under German law, copyright cannot be <em>transferred</em> from one person to another except by inheritance. Does that mean the dedicating a copyrighted work to the public domain is a meaningless statement in Germany?</p>

<p><a href="/questions/tagged/australia" class="post-tag" title="show questions tagged &#39;australia&#39;" rel="tag">australia</a></p>

<p>Assignment and licencing of Copyright is dealt with in <a href="http://www5.austlii.edu.au/au/legis/cth/consol_act/ca1968133/s196.html" rel="nofollow noreferrer">s196</a> of the Copyright Act 1968.</p>

<blockquote>
  <p>Copyright is personal property and, subject to this section, is transmissible by assignment, by will and by devolution by operation of law.</p>
</blockquote>

<p>Whether someone can renounce ownership of personal property under Australian law is not entirely <a href="https://www.dwfoxtucker.com.au/2015/03/finders-keepers-who-owns-abandoned-goods/" rel="nofollow noreferrer">clear</a>. It appears that the answer is probably yes if the owner forms the intention to abandon it. However, that does not make it public domain and the copyright might be able to be claimed by the "finder" of the abandoned property.</p>

<p>There appears to be no provision in the law for "destroying" the personal property that is copyright. Unlike, say, a car, it is not physically possible to destroy copyright.</p>

<p>Notwithstanding, a copyright owner who purports to disclaim copyright has probably granted a permissive, royalty-free, non-revocable, non-revocable, perpetual licence to everyone and this would bind their successors in the copyright which is practically no different from a work that is public domain. Even if this were not the case, the copyright owner would almost certainly be estopped from enforcing copyright against anyone who had taken up their offer of "public domain".</p>

<p>The Netherlands.</p>
<p>Dutch copyright law identifies a number of economic and moral rights that together form &quot;copyright&quot;. Some of these rights can be declined, e.g. the moral right to be identified as the author of the work. This is explicitly stated in the law. By the usual legal interpretation, there is no implied ability to decline the other rights.</p>

copyright