Under the 3 strikes law, the account holder is liable. As the Internet connection is in the landlord's name, the landlord will be liable irrespective of who did the actual infringement.

However, it is possible for landlords to enter into a tenancy contract that specifies that the tenant will be liable. Nothing in copyright law prevents this. The landlord will still get the notices as the account holder and, if things go all the way, fined by the Copyright Tribunal. The landlord can then hold the tenant liable under the separate tenancy contract. It's not that easy as the landlord will have to take action against the tenant for contract enforcement but is perhaps a sufficient deterrent.