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Almost all laws are based on the Berne Convention, so based only on that it'd be too close to call.

Judging by enforcement gives a little more range but is exceptionally subjective; we'll call it a tie among all western countries, because Africa and the Middle and Far East are home to most of the really large-scale piracy and counterfeiting organizations. If the internet were its own country, it'd probably be the worst as far as enforcement goes.

But within the law, there is a range of interpretations. Those that favor owners might be said to be more restrictive, while those that favor users might be said to be less so. That analysis assumes you consider "restrictive" to mean having a narrow interpretation of fair use. In that case, there are certain companies, disciplines, or even individuals who might be considered more restrictive than others.

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Q: Who has the most restrictive copyright?
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