[LosWochosWeek]

This depends on your country and specific copyright laws. These differences exist mostly between common law and roman law countries.

In Germany there is a distinction between copyright holder (Inhaber des Urheberrechts) and the entity that is allowed to act on the copyright (Inhaber des Nutzungsrechts). If I take a picture that you contracted me to take, I'm the former and you're the latter.

[GuB-42]

Same thing in France.

The one who took the picture has moral rights, no matter who hired whom. These rights are for life and not transferrable, you have them whether you want it or not. It also means you can't put your work in the public domain. These are "respect the author" rights that can be use if someone defaces you work for instance. Parody and satire are exceptions.

The one who hired the one who took the picture has patrimonial rights if the contract says so. Patrimonial rights are essentially the right to make money and the closest to US copyright. These are transferrable.