[dba-SQLServer] International law question

I am no lawyer, but I do attempt to stay apprised of current developments
here and in the USA. As I understand the current situation in Canada and in
the USA, it goes like this:
Given a contractor and a client, should they sign a contract for software
development and should the client NOT specify that Client owns the code,
then copyright and ownership of said code belongs to the Developer. (In
Canada this is the case; I think it is the case in the USA as well.)
What is the case in Britain and the ECU? Can anyone on this list provide
info on this? Assume a case in which Contractor A and Client B enter into an
agreement, whose clauses do not specify who owns the code. Further assume
that sometime down the road, Client and Consultant come to loggerheads and
there are arguments, and Consultant wants now to re-use the code and sell it
to other clients in the same industry. (Let's say Dentists, just as an
example.)
What is the European take on this? Can anyone on this list speak to this?
TIA,
Arthur
P.S. 
I am asking this because my latest writing gig (www.simple-talk.com) is
based in England, so I don't want to come off as a provincial from the
colonies. :)