Germany, France, and Britain use a form of so called "right to remain silent," but the prosecutor is allowed to submit silence as evidence of guilt in and of itself.
That is extremely different than a prohibition against self-incrimination.
In France, you actually have to take the stand at trial. However, if you do so under the coercion of the court, you cannot be prosecuted for perjury for anything you say during your testimony. So essentially you can lie, in matters both small and large.
> but the prosecutor is allowed to submit silence as evidence of guilt in and of itself.
In Germany they are not allowed to do that (the police might tell you that, but they tend to be somewhat misleading).
> That is extremely different than a prohibition against self-incrimination.
And this prohibition is actual a central principle of the German law system (and the right to remain silent follows from this).
And the common advice from lawyers here is exactly the same as it is in the US, do use the right to remain silent. Even if you are innocent.. you have nothing to gain by talking (especially without lawyer present).
Huh? What gives you that idea (at least for Germany [0], Switzerland, France(-ish), etc. it is demonstrable false)?
Even the European Court of Human Rights holds that you have the right to remain silent despite there not being a article specifying this as such.
[0] And it does indeed extend to passwords here