While I do agree with this in almost all cases, I have found scenarios where there are actions that don't map easily to a HTTP verb and need something more explicit.
I'm not a purist; for unusual edge cases, I'll put a verb (or something appropriate to the context) at the end of the path. But `create` isn't unusual, just POST to a collection.
What I've generally done in these cases is pretty similar to https://cloud.google.com/apis/design/custom_methods which also explains the problem better than I can.
I'd be interested as to how you'd solve some of these problems without an explicit verb in the path.