Hi,
I understand this is an oldish post but thought i'd comment on this.
I seem to have an inconsistent experience with out of place restores, I have successfully restored out of place to a VM on a different host several times even though the documentation claims they have to be on the same host. Then other times I experience the same error that you recieved.
I like SnapCenter but the documentation is often inconsistent or just plain wrong at times.