However, the taxman has agreed to allow those with an income of less than £30,000 seven years to pay the debt, and those with an income of less than £50,000 five years.
A representative of HMRC said: "HMRC uses reciprocal recovery agreements in combating cross border non-payment of tax debts and will always take the appropriate recourse to recover these debts.
"The deferred renumeration (DR) rules are not specific to UK residents or domiciled individuals. They will apply to any individual with an outstanding DR loan balance, wherever they now choose to work or reside.
"It is an individual’s responsibility to ensure the accuracy of their tax return and to understand the consequences of their decisions.
"DR schemes are examples of contrived tax avoidance that seek a tax advantage that Parliament never intended. It is not normal, or indeed reasonable, to be paid in loans that are unlikely ever to be repaid."