A conservative party calls for new measures to prevent migrants moving abroad to access welfare benefits. The left hits back, defending freedom movement as a cornerstone of the European Union.
A slogan from the conservative party in the ruling coalition government is deemed populist, even racist by the pro-immigration camp - “Those who cheat are out.”
That slogan could have come from UK Prime Minister David Cameron – yet it came from the Christian Social Union (CSU), the Bavarian allies of Chancellor Angela Merkel.
Its leader Horst Seehofer and Cameron have been singing from the same sheet for weeks in attacking perceived benefit tourism among Romanians and Bulgarians.
“Europe should not block us if we want to have national regulation of poverty-driven migration. It is fatal behaviour for Brussels to shut its eyes to this problem and to curb the possibilities for national measures against poverty-driven migration,” the CSU has said.
And the tone of the debate in both countries had been criticized by the Bulgarian government as populist.
Meanwhile benefit tourism has dominated Germany’s media to the extent that the German word for it - Sozialtourismus - was voted the “non-word of the year” for 2013.
Despite the debate over whether restrictions should be placed on Romanians and Bulgarians arriving in Germany filling hundreds of pages in the country’s newspapers, the media is less screechy and populist than in Britain for obvious historical reasons.
Headlines from the Daily Express, The Sun, Daily Mail in Britain on immigration are distasteful in Germany. “Stop new EU migrants flooding in to Britain” would not be found in the German media.
Nora Hesse from think-tank Open Europe Berlin told The Local: “You don’t expect the same level of hysteria in Germany. When the CSU say ‘send them back home,’ it is immediately called populist.
“But both debates focus on two different issues – one is about freedom of movement and the other is access to welfare.”
And this is where the countries diverge. The debate over benefit tourism is based on the same fears. The tone may differ but the worries are the same – migrants will put a burden on our public services and come to take advantage of our generous welfare state.
But in the issue linked to it - the debate over freedom of movement within the EU - Germany will always fall on the side of freedom of movement and the principles of the EU. A poll in December found 55 percent of Germans thought the institution was a "good thing" compared to 26 percent of Britons.
Germany’s Social Democrat foreign minister Frank-Walter Steinmeier said at the start of January that whoever questions freedom of movement “damages Europe and damages Germany".
There is no such voice in Britain’s coalition government. Pro-European Liberal Democrat leader Nick Clegg signed off an article by Cameron in the Financial Times in November calling for a crackdown on EU immigration.
Cameron describes freedom of movement as a “central principle of the EU” but not a “completely unqualified one”.
He questions freedom of movement more than any other EU leader. "When other countries join the European Union we should be insisting on longer transitions and perhaps even saying until you reach a proper share of an average European Union GDP you can't have freedom of movement.
"Perhaps saying until your economy, until your wealth is similar to our wealth you can't have unrestricted movement,” Cameron said in December, before work and travel restrictions were lifted on Bulgarians and Romanians on January 1st.
He has be harder line than Merkel, who publically has stayed out of the debate. A politician from her party, Elmar Brok, who called for Bulgarian and Romanian migrants to be finger-printed was slapped down by her CDU while the Romanian Prime minister accused him of having a "Nazi mind-set".
The German Chancellor, with no Nigel Farage figure to worry about (the leader of the UK Independence Party) and calmer headlines, has let the left and right wings of her coalition scrap it out.
Whereas Cameron is in the frontline of the argument, Merkel has moved just once to respond to benefit immigration fears – she sent the issue to a cabinet working group.