It is vastly different here in the US. A MD/GP has discretionary ability to refill existing ongoing scripts that have been written by someone who was recently seen by a psychiatrist. Substances with highly addictive (and thus strong black market value) potential like Xanax a MD/GP cannot prescribe without special licensure that's heavy regulated. Does that get abused? Of course, because nefarious individuals inhabit all professions and nefarious clients exist. This is why some MD/GP will choose not to refill scripts for people between psychiatrists. That's a massive issue for service providers because what's often done here is a psychiatric assessment before issuing of medication - there's a backlog (aka wait time) for this. While making it discretionary for MD/GP to do so helps to protect the service providers from the few nefarious individuals as service seekers, it screws up others. So when you have those in-between clients where medication access is an issue as without it symptoms return very quickly, service providers have get down and dirty and problem solve these issues fast.
Psychiatrists here have the ability to choose whether they want to do full service (counseling + medication management) or to focus on medication management on a team where the individual counseling is done by counselors/psychologists/social workers. There's more money to be made in straight mediation management and some choose that, but for others it's a practical choice where you have a small team of service providers serving a few communities where it is more practical for the psychiatrist to outsource much of the counseling services because of the sheer volume of individuals seeking services. Even though some psychiatrists who do straight mediation management may literally ask a few questions and write the scirpt, others may do a small bit of additional supportive therapy.
This discussion can get complicated and tangental really quick talking about roles and access and how the system is structured, when trauma occurs from receiving mental health services, etc. Like anything involving humans, it is multilayered and not easily solvable.