Don't mix the "European Copyright" (at least to my understaning) with the bad english word "Copyright".
Yes, you are right they are different.
From what I know, European Copyright is very similar to the German Copyright which rather should be called "Authorship right" because the German name is: "Urheberrecht". It is forbidden by law to give away this property.
Same here: "diritto d'autore". But calling it "property" is not correct.
What you may give away is the Copy-right in the real meaning of the words. This is completely different from the US laws on Copyright.
I don't see them as "completely" different, although there are differences.
For the same reason it is no possible to have public domain software in Europe....
That's interesting. Could you please expand on this?
To my knoledge, a work is told to be in the public domain when the exclusive rights of the author (copy rights) have expired. What you can't give up is the "moral" right of being the author, but that has little practical meaning, as far as I can tell.
/alessandro