miranda abroad

thanks to the wonders of television and film, we've all probably heard police officers informing a suspect's of his/her miranda rights as the latter is arrested. thanks to a landmark case in 1966, police are required to say something along the lines of:

"you have the right to remain silent. anything you say can and will be used against you in a court of law. you have the right to speak to an attorney. if you cannot afford an attorney, one will be appointed to you. do you understand these rights as they have been read to you?"

that most common formulation is, of course, american. it's also not the only permissible description of those rights - i.e. if the cop goes off-script, as long as the above is clear and the suspect is asked whether he/she understands, it counts as legitimate mirandizing. so what about here in canada? in my cursory research, this caught my eye:

"while section 7 of the charter guarantees the right to remain silent, canadian law does not entitle the criminal suspect to have counsel present during the course of an interrogation. once a suspect has asserted their right to counsel, the police are obliged to hold off in attempting to obtain evidence until the suspect has had a reasonable opportunity to contact legal counsel, however suspects do not have the right to have counsel present during the questioning.

"also, in canada even if the suspect emphatically asserts his decision to remain silent, the police may continue to interrogate him." (from wikipedia) so, they can keep asking, he just doesn't have to answer.

in germany, "though the courts may not draw inference from the complete silence of the accused in any stage of criminal proceedings, inference may be drawn if the accused is selectively silent." (also from wikipedia)

while grateful that i live in a country that values these basic rights, i think it's fascinating how each state tweaks the details.