Creating a Document with a specific ID requires history_write
permissions. This is true whether or not the Document has existed in the past.
Create(Ref(Collection(...), {...})
is essentially equivalent to Insert(Ref(Collection(...), Now(), "create", { ... } )
There’s some additional discussion in this topic as to why this requires the “history_write” permission. Why creating a new document with a ref requires the "History Write" permission?