Jon Ingram writeth:

The rule of the lesser or shorter term is from the Berne Convension, not from the EU harmonization directive, and I would therefore expect it to be followed by most countries in the world. Another quote from the article I refer to above:

"However, under the Berne Convention, the Berne rule of the shorter term may apply to works of foreign origin. This rule allows a Berne country to cut off protection of a foreign Berne work at the end of the shorter of two so-called measuring terms: either that applicable in the country where protection is claimed ... or that applicable in the country of origin."

The Berne "rule of the lesser term" was permissive, not mandatory. The EU "rule of the lesser term" is mandatory. And it seems that the UK enacted it in a separate statute in 1995, rather than doing the sensible thing and amending and consolidating the Copyright Act itself. Grrr..