In Italy, for example, all in-hospital deaths of COVID-positive patients are recorded as COVID deaths.
If you're 85 years old, with emphysema, heart disease, diabetes, and COVID, and you die of acute respiratory distress... did COVID kill you?
In Italy, it did, 100%
In New York, it is up to the doctor who declares you dead, but it probably did.
In Germany, it most likely didn't.
That is not to say that Germany isn't doing a good job -- they are. They are doing a lot of testing, isolating, and contact tracing. They are also going full-speed-ahead with the experimental hydroxychloroquine/azithromycin treatment, offering it everyone without contraindications, starting almost from the beginning of the outbreak.
Both of those things contribute to the low death rate.
They are also detecting a higher percentage of cases, which automatically lowers the apparent mortality (since every country detects most of the hospitalizations, more testing means finding more inherently non-lethal cases, meaning more detected recoveries)