Palhinha, 30, joined Tottenham on loan in August after a frustrating single season at the Allianz Arena in which he made only 25 appearances and failed to earn the trust of the coaching staff.
He has been more consistent in north London, making 36 appearances under Roberto De Zerbi, but the club's relegation position complicates any permanent commitment.
Tottenham are currently 18th in the Premier League. Whether they would retain Palhinha in the Championship — and at what wage level — remains an open question.
Bayern are open to a sale and have no plans to reintegrate him, with his contract running until 2028 leaving the German club with limited leverage.
A final decision is not expected before the end of the season.