Benjamin is a Liberian citizen. he has a wife and $3$ children. they reside in Buchana, a city alone Liberia's coastline where Benjamin built a luxurious family home. benjamin is the managing director of ABC Cruises Ltd$,$ a company incorperated in Liberia that operates Boat Cruises along the West African coastline. wishing to extend his business to Mauritus, Benjamin consulted Doris, a Mauritian resident who runs a tax consultancy firm in Mauritus. doris advised Benjamin on how to diversify and extend his boat cruising business to Mauritus. Benjamin forming a partnership with with Doris, which operates Boat Cruises to Mauritus. Benjamin made numerous visits to Mauritus which culminated in Benjamin forming a partnership with Doris, which operates Boats Cruises in Mauritus. In terms of Mauritus' Limited Liability Partnership Act $2016,$ their partnership is registered as a $"$ limited liability partnership" which combines the features of a company and a limited partnership and is treated as a look$-$ through entity for tax purposes. In terms of the partnership agreement, Benjamin is the limited partner. Each partner contributed $50\%$ capital run partnership. The partnership has a bank account in Mauritus to which both Benjamin and Doris are the signators. Eventually Benjamin fell in love with Doris and together they had a son. Benjamin bought for Doris a house in Mauritus where she stays with their son. Since $2015,$ Benjamin spends $6$ months a year in Mauritus and $6$ months in Liberia. In addition, deeply in love with Doris, Benjamin was convinced to obtained a Mauritus' citizenship. Liberia and Mauritus have entered into a double tax treaty that is based on the OECD Model Tax Convention. Assume that in both countries' individuals are deemed resident if they are ordinary in the country or if they spend more than $183$ days in the country in relevant year of assessment. Non$-$residents are taxed on a social basis. Further assuming that thet tax rate in Mauritus and Liberia is $50\%$ and $40\%$ respectively and thta the partnership earned a prifit which is equivalent in terms if United States Dollars is Five Hundred Thousand United States Dollars $(500,000\mathrm{.}00).$

a$.$ With reference to the relevant case supra and applicable treaty provisions, discuss the tax liability of Benjamin in Liberia and Mauritus.

b$.$ With reference to the above distributed profit that you will calculate, what method will be used to relief Benjamin if possible, from double taxation and what will be his repatriated profit that may be or may not be subjected to double taxation given the method of double taxation relief that you may use?

c$.$ Explain the relevance of the Vienna Convention of the Law of Treaties $1969$ to the interpretation of double tax treaties and discuss the provisions of this Convention that can be relied on ensure that the treaty between Liberia and Mauritus is not abused.