No, in logic that is a vacuous truth. All my hats is true for zero hats. But that would not be a lie. And since the liar always lies, that can not be case.
Do you think regular people, when communicating, use academic logic? Or do you think the liar is an academic?
For me, this is one of those types of examples that illustrates the problem with logics allowing vacuous truth.
It amounts to an assumption of an implied conditional ("If I have hats...") which is not always warranted. The "gotcha" here says more about the vacuous truth assumption than it does someone who falls for it.