Given that neither country has a constitution or a guarantee of free speech, there is nothing to wonder at, apart from how much freedom you do actually have.
I think the UK and German restrictions are well balanced, you can say pretty much what you want, as long as you don't call for violence against or the death of other people or ethnic groups, or things like revenge porn. Balanced discussion? Fine. Racial hatred? You need to look at yourself, before opening your mouth.
We are supposed to be living in a civilized world, yet people prove every day that this is not the case; whether it be racial hatred, revenge porn, gun crimes, terrorism or any number of other things.
Having to claim freedom of speech for such things means you have run out of rational arguments, as to why you think such things are acceptable in a civilized society.