Multiculturalism is to Canada as the welfare state is to Britain: Canadians view their multicultural model as distinct from the European version, and as suffering from none of the defects of the latter. Many Europeans do so, too, seeing in the Canadian model the answer to Europe's multicultural problems.

Last month I was invited to give a talk on immigration and citizenship in Europe to a Trudeau Foundation conference in Nova Scotia. For someone like me, a European in favour of mass immigration but critical of multiculturalism, it was a fascinating experience.

The foundation, whose aim is to promote academic research, was set up in 2001 in memory of former Liberal prime minister Pierre Trudeau, and is indelibly shaped by his liberal humanitarianism. Trudeau is particularly associated with the nation's multicultural policy that has come to shape Canadian self-image.

At first glance, there seems much to be said for the success of the Canadian policy. Community relations in Canada have remained relatively peaceful, and there has been far less of the violence and tensions found in Europe. And yet the argument that all is rosy in Canada's multicultural garden is unconvincing.

In Europe, one of the key problems with multicultural policy has been the confusion between the lived experience of diversity and the policies enacted to manage that diversity. The first describes the experience of living in a society that has been made less insular and more vibrant through mass immigration, the second a set of political policies, the aim of which is to manage diversity by putting people into ethnic boxes, and using those boxes to shape public policy.

The irony is that, as a political process, multiculturalism undermines much of what is valuable about the lived experience of diversity. Diversity is important because it allows us to expand our horizons, to think about different values and beliefs, and to engage in political dialogue and debate that can help create a more universal language of citizenship. But it is precisely such dialogue and debate that multicultural policy makes so difficult by boxing people into particular ethnic or cultural categories.

Canadian supporters of multiculturalism insist that their model amounts to a celebration of diversity, rather than the imposition of political policies. Were it so simple. In Canada, as in Europe, individuals with a minority background are often treated as members of a group rather than simply as citizens. In Canada, as in Europe, politicians look to unelected community leaders, often deeply conservative figures, to speak for their particular communities. The underlying problems with multicultural policies do not vanish on crossing the Atlantic. Confrontations over issues such as free speech, public prayers or the wearing of the burqa cast a shadow over Canadian society as much as they do over European ones.

Historically, Canadian multicultural policy developed as a way not of welcoming immigrants but of mitigating the impact of biculturalism – the long-standing tensions between French-speaking Quebec and the rest of English-speaking Canada that have provoked violence and come close to tearing the nation apart. Multiculturalism was initially seen as the ideal means of defusing these tensions, by promoting the idea that, not just the French, but all peoples should have the right to their culture and heritage, and that the preservation of such culture and heritage should be funded by the state. This historical legacy has ensured that Canadian policy, even more that of European nations, is about the public recognition and institutionalisation of cultural differences.

There is a growing movement, for instance, for the creation of segregated schools. Toronto council recently approved a second "Afrocentric" school exclusively for black pupils. There are plans for similar schools for other groups. Not exactly progressive.

Canadians see their multicultural policy as inextricably linked to a liberal immigration policy. Ottawa boasts that Canada has the highest per capita immigration rate in the world. Look more closely, however, and you see a different picture. Canadian policy is largely about cherry-picking middle-class professionals, in particular rich businessmen, and keeping out the "wrong" kind of immigrant by making it almost impossible for unskilled workers to enter. So much so, in fact, that many European nations are now looking to the Canadian system as a model for limiting immigration.

The Canadian economy increasingly requires, however, the kinds of immigrants that Canadian immigration rules deem socially unsuitable to be citizens. To get round this, both business and government now draw upon the services of "temporary workers", who have become the biggest source of new labour in Canada – 182,322 temporary workers arrived in 2010, coming to be fruit pickers, janitors and factory workers; they have few rights and little chance of citizenship.

The irony is that just as European nations are looking to Canada's points system as a way of restricting immigration, Canada is adopting execrable European "guestworker" policies that deny migrants rights and status. This suggests that when it comes to celebrating diversity, Canada has a highly restricted definition of the term. It is the diversity of those who are "like us", not in terms of race or ethnicity, but in terms of class and outlook. Again, the differences with Europe are more apparent than real.

Nothing in the Canadian experience has made me think that here lie the answers to Europe's problems. It has, rather, confirmed my view that multiculturalism is problematic, whichever side of the Atlantic.